B08_Section_J_Attachment_10_307127_Hazardous_Materials_Report.pdf

Tetra Tech, Inc.

7100 Commercial Avenue, Suite 4, Billings, MT 59101

Tel 406.248.9161 Fax 406.248.9282 www.tetratech.com

August 11, 2021

Mr. Will Ives, AIA, Vice President Hennebery Eddy Architects, Inc.

921 SW Washington Street, Suite 250 Portland, Oregon 97205-2827

Delivered via email WIves@henneberyeddy.com

SUBJECT: Hazardous Materials Inspection Report Rehabilitate Exterior of Historical Fort Yellowstone Buildings 17 Historical Housing Units National Park Service Mammoth, Yellowstone National Park, Wyoming Tetra Tech Job Number: 117-8975001

Dear Mr. Ives:

Tetra Tech, Inc. (Tetra Tech) has completed hazardous materials inspection of exterior building components for the below referenced buildings. The purpose of the inspections was to identify asbestos-containing materials (ACM), lead based paint (LBP), mercury-containing components, polychlorinated biphenyl (PCB) containing components, and chlorofluorocarbon (CFC) containing components in preparation for future renovation of the below building’s exteriors.

• FMSS 2815 – Double Captain’s Quarters, 1909, Building 2

• FMSS 3851 – Field Officer’s Quarters, 1909, Building 3

• FMSS 5944 & 5847 – Double Officer’s Quarters, 1897, Buildings 4 & 5

• FMSS 5954 & 5956 – Double Officer’s Quarters, 1891, Buildings 6 & 7

• FMSS 5958 – Army Post Headquarters, 1891, Building 8

• FMSS 5961 – Guard House, 1891, Building 9

• FMSS 6022 – Quartermaster Storehouse, 1891, Building 10

• FMSS 6023 – Commissary, 1891, Building 11

• FMSS 6024 – Granary, 1891, Building 12

• FMSS 6031 – Hospital Sergeant’s Quarters, 1894, Building 14

• FMSS 6056 & 6064 – Noncommissioned Sergeant’s Quarters, 1897, Buildings 30 & 33

• FMSS 6058 & 6062 – Noncommissioned Sergeant’s Quarters, 1891, Buildings 31 & 32

• FMSS 6133 – Lower Mammoth Hot Springs House, 1938, Building HS-83

The following is a summary of the hazardous materials that were identified at the time of the exterior inspection:

Asbestos-Containing Material

• Asbestos-containing materials were identified in association with select components of buildings 3 through 5, 8, 10, 12, 14, 30, 32, and 33.

mailto:wlves@henneberyeddy.com

Hazardous Materials Inspection Report

Rehabilitate Exterior of Historical Fort Yellowstone Buildings 17 Historical Housing Units

National Park Service Mammoth, Yellowstone National Park, Wyoming

August 11, 2021

Lead-Based Paint

• Lead in paint were detected above the United States Environmental Protection Agency (EPA) and United States Department of Housing and Urban development (HUD) definition of lead-based paint on select exterior components of the buildings.

Lead in Soils

• Lead in soil were detected above the EPA defined lead hazard around all exterior portions of buildings 3 through 6, 8 through 12, 14, and 30 through 33.

Mercury-Containing Components

• Mercury-containing components were not identified in association with the exterior of the buildings.

PCB-Containing Components

• PCB-containing components were not identified in association with exterior of the buildings.

Chlorofluorocarbon Components

• CFC-containing components were not identified in association with the exterior of the buildings.

Please refer to the attached report and drawings for more specific information regarding the hazardous materials identified during this hazardous materials inspection.

We appreciate the opportunity to work with you on this project, and we look forward to continuing to provide consulting and engineering services on future projects. If you have questions or need additional information, please contact us at our respective phone numbers.

Respectfully submitted, Tetra Tech, Inc.

Roger W. Herman, Jr.

Roger W. Herman, Jr. Cody Knowlton Asbestos, Lead & IH Services Manager Field Manager & Project Scientist

(406) 248-9161 (406) 208-3540

I:\H-M\Hennebery Eddy Architects\117-8975001 - NPS 17 Housing Units HAZMAT\05-Deliverables\Final\Fort Yellowstone-Hazardous Materials Inspection Report.docx

Enclosed

HAZARDOUS MATERIALS INSPECTION REPORT

REHABILITATE EXTERIOR OF HISTORICAL

FORT YELLOWSTONE BUILDINGS

17 HISTORICAL HOUSING UNITS

NATIONAL PARK SERVICE

MAMMOTH, YELLOWSTONE NATIONAL PARK, WYOMING

Prepared for:

Hennebery Eddy Architects, Inc.

921 SW Washington Street, Suite 250

Portland, Oregon, 97205-2827

Prepared by:

7100 Commercial Avenue, Suite 4

Billings, Montana 59101

Tetra Tech Project No. 117-8975001

August 11, 2021

17 Historical Housing Units National Park Service Mammoth, Yellowstone National Park, Wyoming Hennebery Eddy Architects, Inc.

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TABLE OF CONTENTS

1.0 INTRODUCTION

2.0 REGULATORY CRITERIA

2.1 Asbestos-Containing Material

2.2 Lead-Based Paint

2.3 Lead in Soil

2.4 Mercury-Containing Components

2.5 Polychlorinated Biphenyls-Containing Components

2.6 Chlorofluorocarbons-Containing Components

3.0 INSPECTION METHODOLOGY

3.1 Asbestos-Containing Materials

3.1.1 Asbestos Inspection

3.1.2 Assessment

3.2 Lead-Based Paint

3.3 Lead in Soils

3.4 Mercury-Containing Components

3.5 PCB-Containing Components

3.6 CFC-Containing Components

4.0 FINDINGS

4.1 Asbestos-Containing Material Findings

4.2 Lead-Based Paint Findings

4.4 Lead in Soils Findings

4.5 Mercury-Containing Component Findings

4.6 PCB-Containing Component Findings

4.7 Chlorofluorocarbons-Containing Component Findings

5.0 RECOMMENDATIONS

5.1 Asbestos-Containing Building Materials

5.2 Lead-Based Paint

5.3 Lead in Soils

6.0 LIMITATIONS

LIST OF TABLES

Table 1 Summary of Asbestos Definitions Table 2 Summary of Asbestos Containing Materials Table 3 Summary of Lead-Based Paint Materials Table 4 Summary of Lead in Soils

LIST OF APPENDICES

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Appendix A Asbestos Inspector and EPA LBP Risk Assessor Certifications Appendix B Laboratory Analytical Reports Appendix C XRF Performance Chrematistic Sheet Appendix D Summary of XRF Results Appendix E Educational Information for Landlords Appendix F Figures

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LIST OF ACRONYMS

ACBM Asbestos-containing building material AACM Assumed asbestos-containing material ACM Asbestos-containing material AHERA Asbestos Hazard Emergency Response Act AIHA American Industrial Hygiene Association CFC Chlorofluorocarbons CFR Code of Federal Regulations CY Cubic Yard DOT Department of Transportation EPA United States Environmental Protection Agency HA Homogenous HUD United States Department of Housing and Urban development LF Linear Feet LBP Lead-Based Paint MDL Method Detection Limits mg/L Milligrams Per Liter mg/cm2 Milligrams Per Square Centimeter mg/Kg milligrams per kilogram NESHAP National Emission Standards for Hazardous Air Pollutants ND Non-Detect NPS National Park Service OSHA United States Occupational Safety and Health Administration PCB Polychlorinated biphenyls PLM Polarized light microscopy PPE Personal Protective Equipment RACM Regulated Asbestos-Containing Materials RCRA Resource Conservation and Recovery Act RRP Renovation, Repair and Painting Rule SF Square Feet TCLP Toxic Characteristics Leaching Procedure WDEQ Wyoming Department of Environmental Quality µg /kg Micrograms Per Kilograms XRF X-Ray Fluorescence

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1.0 INTRODUCTION

At the direction of Hennebery Eddy Architects, Inc (HEA), a hazardous materials inspection of exterior building components was conducted on the following buildings located at the Historical Fort Yellowstone in Mammoth, Yellowstone National Park, Wyoming.

• FMSS 2815 – Double Captain’s Quarters, 1909, Building 2

• FMSS 3851 – Field Officer’s Quarters, 1909, Building 3

• FMSS 5944 & 5847 – Double Officer’s Quarters, 1897, Buildings 4 & 5

• FMSS 5954 & 5956 – Double Officer’s Quarters, 1891, Buildings 6 & 7

• FMSS 5958 – Army Post Headquarters, 1891, Building 8

• FMSS 5961 – Guard House, 1891, Building 9

• FMSS 6022 – Quartermaster Storehouse, 1891, Building 10

• FMSS 6023 – Commissary, 1891, Building 11

• FMSS 6024 – Granary, 1891, Building 12

• FMSS 6031 – Hospital Sergeant’s Quarters, 1894, Building 14

• FMSS 6056 & 6064 – Noncommissioned Sergeant’s Quarters, 1897, Buildings 30 & 33

• FMSS 6058 & 6062 – Noncommissioned Sergeant’s Quarters, 1891, Buildings 31 & 32

• FMSS 6133 – Lower Mammoth Hot Springs House, 1938, Building HS-83

The purpose of the inspection was to identify asbestos-containing materials (ACM), lead-based paint (LBP), lead in soil, mercury-containing components, polychlorinated biphenyl (PCB) containing components, and chlorofluorocarbon (CFC) containing components in preparation for future rehabilitation of exterior portions of the buildings. This report consists of the following sections:

• Tetra Tech’s scope of services,

• Applicable regulations pertaining to the inspection,

• Inspection methodology,

• Inspection findings, and

• Recommendations.

The field work was conducted by Mr. Cody Knowlton on June 21 through 28, 2021, The asbestos inspection was conducted in accordance with the National Emission Standards for Hazardous Air Pollutants (NESHAP) and the Asbestos Hazard Emergency Response Act (AHERA), as administered by the State of Wyoming Department of Environmental Quality (WDEQ). Tetra Techs AHERA Accredited Asbestos Inspector collected samples of exterior suspect ACM. His Asbestos Inspector Accreditation Certification is presented in Appendix A.

Tetra Tech conducted LBP survey of the buildings using X-Ray Fluorescence (XRF) methodology to determine the presence of LBP on exterior building components. Tetra Techs United States Environmental Protection Agency (EPA) lead risk assessor Mr. Cody Knowlton collected the XRF and lead soil samples. His EPA Lead Risk Assessor certification is presented in Appendix A. Laboratory analytical reports are presented in Appendix B. The Performance Characteristic Sheet for the LBP testing instrument is presented in Appendix C, results of the LBP inspection are contained in Appendix D, the Educational Information for Landlords brochure is contained in Appendix E, and Approximate sample collection locations, ACM locations, and LBP locations are presented on Figures in Appendix F.

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The scope of services for this inspection included:

• Visual examination of building exteriors for suspect ACM,

• Collection of samples of suspected ACM for laboratory analyses,

• Field testing of building exteriors components for suspect LBP,

• Collection of samples and visual examination of building exteriors for lead in soils

• Visual examination of building exterior for components considered to be mercury-containing,

• Visual examination of building exteriors for components considered to be PCB-containing,

• Visual examination of building exteriors for components considered to be CFC-containing,

• Evaluation of analytical data and,

• Preparation of this final report which outlines the hazardous substances identified in association with the buildings.

2.0 REGULATORY CRITERIA

2.1 Asbestos-Containing Material

The application, removal, and disposal of asbestos-containing materials are regulated by several agencies. Worker exposure to asbestos during construction operations including ACM removal is regulated under 29 Code of Federal Regulations (CFR) 1926.1101. The United States Occupational Safety and Health Administration (OSHA) has established worker protection measures during the removal of asbestos from the facilities including, but not limited to training and medical monitoring requirements for personnel engaging in the oversight and removal of ACM, exposure limits, respiratory protection, personal protective equipment (PPE), work practices and engineering controls, and storage of wastes.

The removal and disposal of ACM is regulated under the asbestos NESHAP, 40 CFR Part 61, Subpart M. Table 1 presents a summary of pertinent EPA definitions under 40 CFR 763.83, as administered by the WDEQ.

Table 1 Summary of Asbestos Definitions

Asbestos-Containing Materials (ACM) Materials containing more than one percent (1%) asbestos

Asbestos-Containing Building Materials (ACBM)

ACM that is in or on interior structural members or other parts of a public or commercial building.

Assumed Asbestos- Containing Material (AACM)

ACM that remains un-sampled, but is considered suspect to be asbestos-containing, and must be treated as ACM until proven not to be asbestos-containing by laboratory analysis.

Friable ACM Ability of material to be crumbled, pulverized or reduced to powder when dry with hand pressure as determined by physical touching by asbestos building inspector.

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2.2 Lead-Based Paint

EPA and United States Department of Housing and Urban development (HUD) define LBP as any surface coatings with a lead concentration greater than or equal to 1.0-milligram per square centimeter (mg/cm2) or 0.5 percent by weight (40 CFR Part 745 and Title X). Deteriorated LBP can cause elevated lead in dust levels and exposure risks to building occupants.

The EPA’s regulations on residential property renovation (40 CFR 745 Subpart E) Lead Renovation, Repair and Painting (RRP) Rules requires that firms performing renovation, repair and painting projects that disturb lead-based paint in homes, childcare facilities and pre-schools built before 1978 be certified by EPA (or an EPA-authorized state), use certified renovators who are trained by EPA-approved training providers and follow lead-safe work practices. Safe work practices may include use of PPE (respiratory protector, disposable coveralls, and eye protection), initial exposure assessment, and use of wet methods.

2.3 Lead in Soil

The EPA currently recognizes Residential Lead Hazard Standards as greater than 1,200 milligrams per kilogram (mg/Kg) of lead in bare soils in non-play areas. Due to the potential for occupancy of the buildings by occupants who have increased susceptibility to lead exposure (i.e., pregnant women and or children), Tetra Tech recommends that the National Park Service (NPS) utilize the hazard levels established by the EPA Residential Lead Hazard Standards as a guideline for the determination of exposure risk.

The EPA’s regulations on residential property renovation (40 CFR 745 Subpart E) Lead Renovation, RRP Rule requires that firms performing renovation, repair and painting projects that disturb lead-based paint in homes, childcare facilities and pre-schools built before 1978 be certified by EPA (or an EPA-authorized state), use certified renovators who are trained by EPA-approved training providers and follow lead-safe work practices. Safe work practices may include use of PPE (respiratory protector, disposable coveralls, and eye protection), initial exposure assessment, and use of wet methods.

2.4 Mercury-Containing Components

Free (liquid) mercury or mercury vapor in components can be a source of mercury leaching into the environment and is identified as a characteristic hazardous waste (D009) under 40 CFR.261.24 and 273 and the WDEQ Chapter 1, Section 273. Based on the identification as a hazardous waste, mercury-containing fixtures and equipment must be disposed of at a registered hazardous waste facility.

Management and disposal by businesses of fluorescent light bulbs and other mercury-containing bulbs are regulated under the Resource Conservation and Recovery Act (RCRA) and the Universal Waste Rule. The WDEQ has provided regulatory guidance for the disposal of fluorescent bulbs and ballasts.

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2.5 Polychlorinated Biphenyls-Containing Components

PCBs in ballasts, electrical components, and other building materials can be a dermal hazard and a source of PCBs leaching into the soil. Transport and disposal of PCBs must comply with 40 CFR 761.62, WDEQ Chapter 1, Section 273, and must comply with applicable Department of Transportation (DOT) requirements.

2.6 Chlorofluorocarbons-Containing Components

Freon gas includes a number of gaseous, colorless CFCs that are commonly used as refrigerants. The EPA regulates the emission of Freon gas into the atmosphere due to its ozone depleting capabilities. Through Title VI, Stratospheric Ozone Protection, of the Clean Air Act Amendments of 1990, the EPA regulates Freon gas and requires mandatory recycling and a ban on the intentional venting or releasing of refrigerants.

3.0 INSPECTION METHODOLOGY

The hazardous materials inspection was intrusive in nature. The intrusive assessment attempted to identify concealed building materials such as: vapor barriers under roofing systems, concealed building materials located behind walls. While the inspection endeavored to identify all potentially hazardous substances, users of this report should be aware that the sampling program has some limitations given the fact that some materials, by their very nature, may be concealed underground, behind walls, etc. or due to other potential site safety hazards.

The assessments focused on the following designated substances.

3.1 Asbestos-Containing Materials

3.1.1 Asbestos Inspection

Suspected ACMs were grouped as homogeneous areas if the material was uniform in appearance and texture. However, if the inspector decided that a material (for example, vapor barrier) was not similar in appearance and texture to other materials on the buildings, the inspector distinguished the material as unique and collected samples of each unique material.

Bulk samples collected were placed in plastic bags, labeled, and sealed immediately upon collection. The sampling instruments were wiped clean with cleaning wipes after the collection of each sample to prevent cross-contamination between samples. A unique sample identification number was assigned to each sample in general accordance with the following format:

• YNP#2-M1.1A

Where “YNP#2” would reference the buildings ID; “M1” would reference the material type, in this case, a roofing material; “1” would reference that this was the first type of material identified, and “A” would reference the first of three (to seven) samples associated with the homogeneous material.

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Upon completion of sampling activities, the bulk samples were delivered, along with completed chain-of-custody documentation, to Crisp Analytical (Crisp) of Carrollton, Texas.

Crisp is accredited by the American Industrial Hygiene Association (AIHA) for bulk asbestos sample analysis, which was performed using polarized light microscopy (PLM) in accordance with the EPA Interim Method 600/R-93/116 (improved), for identification of mineral forms of asbestos. The quantification of asbestos in the sample is intended to be a visual estimate only and the limit of detection for this method is approximately 1% by volume.

3.1.2 Assessment

Homogeneous ACBM were identified following receipt of the laboratory analyses. The materials were then categorized using the following NESHAP criteria under 40 CFR Part 61, Subpart M:

1) Category I are non-friable asbestos-containing packings, gaskets, resilient floor covering, and asphalt roofing products.

2) Category II are non-friable ACBM excluding Category I non-friable ACBM.

3) Regulated Asbestos-Containing Materials (RACM) are friable materials; Category I non-friable ACM that has become friable; Category I non-friable materials that will or may be subjected to sanding, grinding, cutting, or abrading; or Category II non-friable materials that have a high probability of becoming or have become crumbled, pulverized, or reduced to powder by forces expected to act on the material in the course of demolition or renovation operations.

3.2 Lead-Based Paint

Components tested during this LBP inspection included all accessible exterior components.

Tested painted components were cataloged based on location, specific component type, and substrate material.

EPA and HUD define LBP inspection as a surface-by-surface investigation to determine the presence of LBP. Tetra Tech generally followed the HUD LBP inspection guidelines (HUD, 1995, revised 1997 and 2000) for the purposes of this inspection1. The EPA and HUD define LBP as any surface coating that contains 1.0 mg/cm² or 0.5% by weight.

Tetra Tech used field X-Ray Fluorescence (XRF) methodology to determine the presence or absence of LBP. XRF is identified as the recommended method to determine lead in paint. Tetra Tech personnel utilized the Niton XLP, Spectrum Analyzer XRF for these inspections, which automatically calculates measurable amounts of lead in paint by correcting for substrate conditions. The XRF Performance Characteristic Sheet for the XRF used by Tetra Tech specifies the ranges where XRF results are positive, negative, or inconclusive.

1 As specified in Housing and Urban Development, Guidelines for the Control of Lead-Based Paint Hazards in Housing, June 1995, revised 1997 and

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3.3 Lead in Soils

The assessment included sample collection and visual inspection of the building exterior for signs of paint chips, worn or deteriorating paint, and bare soils where children are known to play. Soil samples were collected as eight to sixteen aliquot composites, with sample depths consisting of 0 to 2 inches below the soil surface. Sample collection was conducted in accordance with EPA Residential Sampling for Lead: Protocols for Dust and Soil Sampling.

Upon completion of sampling activities, the soil samples were delivered, along with completed chain-of-custody documentation, to EMSL Analytical, Inc. (EMSL) of Cinnaminson, New Jersey.

EMSL is accredited by the AIHA for lead analysis, which was performed using Flame AAS in accordance with the EPA Method SW 846 7000B. The limit of detection for this method is 40 mg/Kg.

3.4 Mercury-Containing Components

The assessment included the visual inspection of mercury-containing equipment including compact fluorescent lamps, fluorescent U-tubes, fluorescent lamps, linear fluorescent lamps, mercury vapor lamps, metal halide lamps, sodium vapor lamps, thermostats, temperature probes, batteries, and flow meters, as well as miscellaneous components (if present) identified during the course of the inspection. The final portion of the inspection consisted of Tetra Tech personnel opening and disassembling the component to observe whether or not the component had labels indicating mercury content. Where applicable, the components’ manufacturing information was compared against a listing of mercury-containing components provided by the EPA. Any components that were suspected of containing mercury and were either not labeled or did not have labels identifying them as “Mercury-Free” were assumed to be mercury-containing and were documented accordingly.

3.5 PCB-Containing Components

The assessment included the visual inspection and sampling of miscellaneous components identified during the course of the inspection historically identified as PCB-containing, including but not limited to air conditioners, capacitors, equipment with electrical motors, freezers, furnace blower motors, hydraulic equipment, light ballasts, switches, transformers, and a plasticizing agent for caulking and glazing materials. The final part of the inspection consisted of Tetra Tech personnel opening the fluorescent lights to observe whether or not the ballasts had labels stating their PCB content. When applicable, the components’ manufacturing information was compared against a listing of PCB-containing components provided by the EPA. Any components that were suspected of containing-PCBs and were either not labeled or did not have labels identifying them as “PCB-Free” were assumed to be PCB-containing and were documented accordingly.

3.6 CFC-Containing Components

The assessment included the visual inspection of miscellaneous components identified during the course of the inspection historically identified as CFC-containing, including but not limited to air conditioners, compressor tanks, coolers, and freezers. When applicable, the components’ manufacturing information was compared against a listing of CFC-containing components provided by the EPA. Any components that were suspected of containing CFCs and were either not labeled or did not have labels identifying them as “Chlorofluorocarbons-Free” were assumed to be CFC-containing and were documented accordingly.

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4.0 FINDINGS

The results of the exterior inspection activities are described in the following sections.

4.1 Asbestos-Containing Material Findings

A summary of exterior ACMs is provided on Table 2. Approximate sample collection locations and approximate ACM locations are presented on attached Figures.

Table 2 Summary of ACM

HA Number Material Description Percent Asbestos Material Type NESHAP

Category Estimated Quantity

Estimated Abatement Cost

Building 2

No Exterior Asbestos-Containing Materials

Building 3

YNP#3-M29.2 Window glazing associated with windows

4% Chrysotile Miscellaneous Category II

Non-Friable 47 Windows

Building 4

YNP#4-M29.2 Window glazing associated with windows

3% Chrysotile Miscellaneous Category II

Non-Friable 62 Windows

Building 5

YNP#5-M29.2 Window glazing associated with windows

2% Chrysotile Miscellaneous Category II

Non-Friable 48 Windows

Building 6

No Exterior Asbestos-Containing Materials

Building 7

No Exterior Asbestos-Containing Materials

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Table 2 Summary of ACM

HA Number Material Description Percent Asbestos Material Type NESHAP

Category Estimated Quantity

Estimated Abatement Cost

Building 8

YNP#8-M29.2

Window glazing associated with windows

(west side original building)

2% Chrysotile Miscellaneous Category II

Non-Friable

15 Windows

YNP#8-M29.3

Window glazing associated with windows east side addition

2% Chrysotile Miscellaneous Category II

Non-Friable

Building 9

No Exterior Asbestos-Containing Materials

Building 10

YNP#10-

M29.1

Window glazing associated with storm windows

3% Chrysotile Miscellaneous Category II

Non-Friable 39 Windows

YNP#10-

M29.2

Window glazing associated with windows

2% Chrysotile Miscellaneous Category II

Non-Friable

Building 11

No Exterior Asbestos-Containing Materials

Building 12

YNP#12-

M29.2

Window glazing associated with windows

2% Chrysotile Miscellaneous Category II

Non-Friable 39 Windows

Building 14

YNP#14-

M29.1

Window glazing associated with storm windows

4% Chrysotile Miscellaneous Category II

Non-Friable 14 Windows

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Table 2 Summary of ACM

HA Number Material Description Percent Asbestos Material Type NESHAP

Category Estimated Quantity

Estimated Abatement Cost

Building 30

YNP#30-

M45.1

White rubber membrane roofing system ASSUMED Miscellaneous Category I

Non-Friable 400 SF

Building 31

No Exterior Asbestos-Containing Materials

Building 32

YNP#32-

M29.1

Window glazing associated with storm windows

2% Chrysotile Miscellaneous Category II

Non-Friable 18 Windows

Building 33

YNP#33-

M29.1

Window glazing associated with storm windows

3% Chrysotile Miscellaneous Category II

Non-Friable 15 Windows

Building HS-83

No Exterior Asbestos-Containing Materials

Asbestos Abatement

Design Services

Clearance Services

10% Contingency

TOTAL ASBESTOS PROJECT COSTS ESTIMATED

HA = Homogeneous Area Number, NESHAP = National Emission Standard for Hazardous Air Pollutants, and SF = Square Feet

The following materials sampled from the buildings were suspected to contain asbestos but were confirmed by laboratory analyses not to contain asbestos:

Building 2

• Black felt paper under red ceramic tile roof (YNP#2-M1.1A, B, C)

• Red ceramic roofing tiles (YNP#2-M1.2A, B, C)

• Gray concrete associated with sidewalks and stairs (YNP#2-M18.1A, B, C)

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• Gray painted white window glazing associated with interior windows (YNP#2-M29.2A, B, C)

• Gray mortar associated with sandstone brick foundation (YNP#2-M30.1A, B, C)

• Gray mortar associated with windows and door frames (YNP#2-M30.2A, B, C)

Building 3

• Black felt paper under red ceramic tile roof (YNP#3-M1.1A, B, C)

• Red ceramic roofing tiles (YNP#3-M1.2A, B, C)

• Gray concrete associated with sidewalks and stairs (YNP#3-M18.1A, B, C)

• Gray painted white window glazing associated with storm windows (YNP#3-M29.1A, B, C)

• Gray mortar associated with sandstone brick foundation (YNP#3-M30.1A, B, C)

• Gray mortar associated with windows and door frames (YNP#3-M30.2A, B, C)

Building 4

• Black felt paper under red painted metal tile roof (YNP#4-M1.1A, B, C)

• Gray concrete associated with sidewalks (YNP#4-M18.1A, B, C)

• Black vapor barrier under wood siding (YNP#4-M20.1A, B, C)

• Gray painted white window glazing associated with storm windows (YNP#4-M29.1A, B, C)

• Red painted gray mortar and orange brick associated with chimneys (YNP#4-M30.1A, B, C)

• Gray mortar associated with foundation stones (YNP#4-M30.2A, B, C)

Building 5

• Black felt paper under red painted metal tile roof (YNP#5-M1.1A, B, C)

• Gray concrete associated with sidewalks (YNP#5-M18.1A, B, C)

• Black vapor barrier under wood siding (YNP#5-M20.1A, B, C)

• Gray painted white window glazing associated with storm windows (YNP#5-M29.1A, B, C)

• Red painted gray mortar and orange brick associated with chimneys (YNP#5-M30.1A, B, C)

• Gray mortar associated with foundation stones (YNP#5-M30.2A, B, C)

Building 6

• Black felt paper under red painted metal tile roof (YNP#6-M1.1A, B, C)

• Gray concrete associated with sidewalks (YNP#6-M18.1A, B, C)

• Black vapor barrier under wood siding (YNP#6-M20.1A, B, C)

• Gray painted white window glazing associated with storm windows (YNP#6-M29.1A, B, C)

• Gray painted white window glazing associated with interior windows (YNP#6-M29.2A, B, C)

• Red painted gray mortar and orange brick associated with chimneys (YNP#6-M30.1A, B, C)

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• Gray mortar associated with foundation stones (YNP#6-M30.2A, B, C)

Building 7

• Black felt paper under red painted metal tile roof (YNP#7-M1.1A, B, C)

• Gray concrete associated with sidewalks (YNP#7-M18.1A, B, C)

• Brown vapor barrier under wood siding (YNP#7-M20.1A, B, C)

• Gray painted white window glazing associated with storm windows (YNP#7-M29.1A, B, C)

• Gray painted white window glazing associated with interior windows (YNP#7-M29.2A, B, C)

• Red painted gray mortar and orange brick associated with chimneys (YNP#7-M30.1A, B, C)

• Gray mortar associated with foundation stones (YNP#7-M30.2A, B, C)

Building 8

• Black felt paper under red painted metal tile roof (YNP#8-M1.1A, B, C)

• Black felt paper under cedar shake roof (YNP#8-M1.2A, B, C)

• Gray concrete associated with sidewalks (YNP#8-M18.1A, B, C)

• Orange vapor barrier under wood siding east side addition (YNP#8-M20.1A, B, C)

• Brown vapor barrier under wood siding west side original building (YNP#8-M20.2A, B, C)

• Gray painted white window glazing associated with storm windows (YNP#8-M29.1A, B, C)

• Red painted gray mortar and orange brick associated with chimneys (YNP#8-M30.1A, B, C)

• Gray mortar associated with foundation stones (YNP#8-M30.2A, B, C)

Building 9

• Black felt paper under red painted metal tile roof (YNP#9-M1.1A, B, C)

• Gray concrete associated with sidewalks (YNP#9-M18.1A, B, C)

• Gray concrete associated with foundation (YNP#9-M18.2A, B, C)

• Brown vapor barrier under wood siding (YNP#9-M20.1A, B, C)

• Gray painted white window glazing associated with storm windows (YNP#9-M29.1A, B, C)

• Gray painted white window glazing associated with interior windows (YNP#9-M29.2A, B, C)

• Red painted gray mortar and orange brick associated with chimneys (YNP#9-M30.1A, B, C)

• Gray mortar associated with foundation stones (YNP#9-M30.2A, B, C)

Building 10

• Black felt paper under red painted metal tile roof (YNP#10-M1.1A, B, C)

• Black tar associated with gray block chimney flashing (YNP#10-M1.2A, B, C)

• Gray concrete associated with sidewalks (YNP#10-M18.1A, B, C)

• Brown vapor barrier under wood siding (YNP#10-M20.1A, B, C)

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• Red painted gray mortar and orange brick associated with chimneys (YNP#10-M30.1A, B, C)

• Gray mortar associated with foundation stones (YNP#10-M30.2A, B, C)

• Gray mortar and gray block associated with chimneys (YNP#10-M30.3A, B, C)

Building 11

• Black felt paper under red painted metal tile roof (YNP#11-M1.1A, B, C)

• Gray concrete associated with sidewalks (YNP#11-M18.1A, B, C)

• Gray painted white window glazing associated with storm windows (YNP#11-M29.1A, B, C)

• Gray painted white window glazing associated with interior windows (YNP#11-M29.2A, B, C)

• Red painted gray mortar and orange brick associated with chimneys (YNP#11-M30.1A, B, C)

• Gray mortar associated with foundation stones (YNP#11-M30.2A, B, C)

• Gray mortar and gray block associated with chimneys (YNP#11-M30.3A, B, C)

Building 12

• Black felt paper under red painted metal tile roof (YNP#12-M1.1A, B, C)

• Gray concrete associated with sidewalks (YNP#12-M18.1A, B, C)

• Brown vapor barrier under wood siding (YNP#12-M20.1A, B, C)

• Gray painted white window glazing associated with storm windows (YNP#12-M29.1A, B, C)

• Red painted gray mortar and orange brick associated with chimneys (YNP#12-M30.1A, B, C)

• Gray mortar associated with foundation stones (YNP#12-M30.2A, B, C)

• Gray mortar and gray block associated with chimneys (YNP#12-M30.3A, B, C)

Building 14

• Black felt paper under red painted metal tile roof (YNP#14-M1.1A, B, C)

• Gray concrete associated with sidewalks, stairs, and vaults (YNP#14-M18.1A, B, C)

• Brown vapor barrier under wood siding (YNP#14-M20.1A, B, C)

• Gray painted white window glazing associated with interior windows (YNP#14-M29.2A, B, C)

• Red painted gray mortar and orange brick associated with chimneys (YNP#14-M30.1A, B, C)

• Gray mortar associated with foundation stones (YNP#14-M30.2A, B, C)

Building 30

• Black felt paper under red painted metal tile roof (YNP#30-M1.1A, B, C)

• Gray concrete associated with sidewalks, stairs, and foundation (YNP#30-M18.1A, B, C)

• Brown vapor barrier under wood siding (YNP#30-M20.1A, B, C)

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• Gray painted white window glazing associated with storm windows (YNP#30-M29.1A, B, C)

• Gray painted white window glazing associated with interior windows (YNP#30-M29.2A, B, C)

• Red painted gray mortar and orange brick associated with chimneys (YNP#30-M30.1A, B, C)

• Gray mortar associated with foundation stones (YNP#30-M30.2A, B, C)

Building 31

• Black felt paper under red painted metal tile roof (YNP#31-M1.1A, B, C)

• Black rolled roofing under red roofing tiles utility room (YNP#31-M1.2A, B, C)

• Gray concrete associated with sidewalks and foundation (YNP#31-M18.1A, B, C)

• Brown vapor barrier under wood siding (YNP#31-M20.1A, B, C)

• Gray painted white window glazing associated with storm windows (YNP#31-M29.1A, B, C)

• Gray painted white window glazing associated with interior windows (YNP#31-M29.2A, B, C)

• Red painted gray mortar and orange brick associated with chimneys (YNP#31-M30.1A, B, C)

• Gray mortar associated with foundation stones (YNP#31-M30.2A, B, C)

Building 32

• Black felt paper under red painted metal tile roof (YNP#32-M1.1A, B, C)

• Gray concrete associated with sidewalks (YNP#32-M18.1A, B, C)

• Brown vapor barrier under wood siding (YNP#32-M20.1A, B, C)

• Gray painted white window glazing associated with interior windows (YNP#32-M29.2A, B, C)

• Red painted gray mortar and orange brick associated with chimneys (YNP#32-M30.1A, B, C)

• Gray mortar associated with foundation stones (YNP#32-M30.2A, B, C)

Building 33

• Black felt paper under red painted metal tile roof (YNP#33-M1.1A, B, C)

• Gray concrete associated with sidewalks and window vaults (YNP#33-M18.1A, B, C)

• Brown vapor barrier under wood siding (YNP#33-M20.1A, B, C)

• Gray painted white window glazing associated with interior windows (YNP#33-M29.2A, B, C)

• Red painted gray mortar and orange brick associated with chimneys (YNP#33-M30.1A, B, C)

• Gray mortar associated with foundation stones (YNP#33-M30.2A, B, C)

Building 83

• Black felt paper and marron shingles (YNP#83-M1.1A, B, C)

• Gray concrete associated with foundation (YNP#83-M18.1A, B, C)

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• Brown vapor barrier under wood siding (YNP#83-M20.1A, B, C)

• White painted white window glazing associated with windows (YNP#83-M29.1A, B, C)

• Red painted gray mortar and orange brick associated with chimneys (YNP#83-M30.1A, B, C)

• Black foundation sealant (YNP#83-M31.1A, B, C)

4.2 Lead-Based Paint Findings

XRF data indicated that LBP, as defined by EPA and HUD, is present. XRF data also indicated that lead is present at concentrations less than the EPA and HUD limit of 1.0 mg/cm² and greater than

0.02 mg/cm². A complete listing of all XRF readings collected during this inspection is provided in Attachment D.

A summary of the EPA defined LBP identified during this exterior inspection is provided on Table 3. Approximate locations of the LBP components are presented on attached Figures.

Table 3 Summary of LBP

Component and General Description

Observed Condition

Highest Lead Concentration mg/cm2

Estimated Quantity

Estimated Abatement Cost

Building 2 Gray paint on wood doors, door components, and tan paint on wood trim

Fair 42.0 6 Doors

Gray paint on wood windows, window components, and tan paint on wood trim Fair 42.6 66 Windows

Tan paint on wood porch railings, columns, soffit, and facia Fair 41.6 400 SF

Tan paint on wood soffit and fascia Fair 41.5 1,200 SF

Gray paint on wood porch floor Fair 27.1 120 SF

Beige paint on metal gutters and downspouts Fair 20.2 380 LF

Tan paint on metal utility hatch Fair 9.1 2 EA

Building 3

Tan paint on wood soffit and fascia Fair 27.2 1,000 SF

Beige paint on metal gutters and downspouts Fair 41.1 320 LF

Gray paint on wood doors, door components, and tan paint on wood trim Fair 28.1 5 Doors

Gray painted wood windows, window components, storm windows, and tan paint on wood trim Fair 39.2 47 Windows

3 Storm Windows

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Table 3 Summary of LBP

Component and General Description

Observed Condition

Highest Lead Concentration mg/cm2

Estimated Quantity

Estimated Abatement Cost

Gray paint on wood porch floor Fair 10.4 130 SF

Tan paint on wood porch trim, columns, supports, soffit, and facia Fair 48.7 770 SF

Building 4 Tan paint on wood porch railing, trim, columns, supports, soffit, facia, and beige paint on wood lattice

Poor 30.8 525 SF

Red paint on metal roofing tiles Fair 10.1 6,100 SF

Beige paint on wood lap siding shingle siding, and tan paint on wood trim Poor 37.3 8,100 SF

Gray paint on wood windows, window components, storm windows, and tan paint on wood trim Poor 37.6 62 Windows

1 Storm Window

Gray paint on wood porch floor Poor 12.1 130 SF

Beige paint on metal gutters and downspouts Poor 10.8 550 LF

Tan paint on wood soffit and fascia Poor 36.8 1,650 SF

Gray paint on wood doors, door components, and tan paint on wood trim Fair 28.2 6 Doors

Building 5 Tan paint on wood porch railing, trim, columns, supports, soffit, facia, and beige paint on wood lattice

Poor 37.2 525 SF

Beige paint on wood lap siding, shingle siding, and tan paint on wood trip Poor 33.9 8,100 SF

Beige paint on metal gutters and downspouts Poor 7.2 550 LF

Gray paint on wood doors, door components, and tan paint on wood trim Fair 22.1 6 Doors

Gray paint on wood screen doors Fair 29.5 2 Doors

Gray paint on wood porch floor Poor 2.6 520 SF

Red paint on metal roofing tiles Fair 10.1 6,100 SF

Gray paint on wood windows, window components, storm windows, and tan paint on wood trim Poor 36.7 48 Windows

6 Storm Windows

Tan paint on wood soffit and fascia Poor 34.2 1,650 SF

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Table 3 Summary of LBP

Component and General Description

Observed Condition

Highest Lead Concentration mg/cm2

Estimated Quantity

Estimated Abatement Cost

Building 6

Gray paint on wood windows, window components, storm windows, dormer windows, and tan paint on wood trim

Poor 30.4 50 Windows 5 Storm Windows

Red paint on metal roofing tiles Fair 18.2 6,100 SF

Tan paint on wood soffit and fascia Poor 26.8 1,650 SF

Tan paint on wood porch railing, trim, columns, supports, soffit, facia, and beige paint on wood lattice Poor 33.8 450 SF

Beige paint on wood lap siding, shingle siding, and tan paint on wood trim Poor 33.8 8,100 SF

Gray paint on wood doors, door components, and tan paint on wood trim Fair 30.4 6 Doors

Beige paint on metal gutters and downspouts Poor 7.4 550 LF

Gray paint on wood porch floor Poor 6.1 130 SF

Building 7

Tan paint on wood porch railing, trim, columns, supports, soffit, facia, and beige wood lattice Poor 33.4 360 SF

Tan paint on wood soffit and fascia Poor 32.8 1,650 SF

Gray paint on wood doors, door components, and tan paint on wood trim Fair 28.9 6 Doors

Beige paint on wood lap siding, shingle siding, and tan paint on wood trim Poor 40.9 8,100 SF

Gray paint on wood windows, window components, storm windows, dormer windows, and tan paint on wood trim

Poor 30.4 48 Windows 4 Storm Windows

Beige paint on metal gutters and downspouts Poor 10.0 480 LF

Red paint on brick chimney Fair 2.1 240 SF

Red paint on metal roofing tiles Fair 9.6 6,100 SF

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Table 3 Summary of LBP

Component and General Description

Observed Condition

Highest Lead Concentration mg/cm2

Estimated Quantity

Estimated Abatement Cost

Building 8 Gray paint on wood doors, door components, and tan paint on wood trim

Fair 19.7 2 Doors

Tan paint on wood porch décor, trim, columns, supports, soffit, and facia Poor 34.8 120 SF

Beige paint on wood lap siding, shingle siding, and tan paint on wood trim Poor 30.1 3,270 SF

Tan paint on wood soffit and fascia Poor 30.7 1,240 SF

Gray paint on wood porch floor Poor 8.0 390 SF

Beige paint on metal gutters and downspouts Poor 36.4 140 LF

Beige paint on metal crawl space vents Poor 10.7 8 EA

Gray paint on wood windows, window components, storm windows, and tan paint on wood trim Poor 34.8 15 Windows

2 Storm Windows

Red paint on metal roofing tiles Fair 24.1 1,800 SF

Building 9 Beige paint on wood lap siding and tan paint on wood trim Poor 50.0 3,500 SF

Gray paint on wood screen doors Fair 3.9 2 Doors

Gray paint on wood doors, door components, and tan paint on wood trim Poor 39.2 4 Doors

Tan paint on wood windows, window components, storm windows, and tan paint on wood trim Poor 39.2 31 Windows

14 Storm Windows

Tan paint on wood soffit and fascia Poor 26.0 1,020 SF

Beige paint on metal gutters and downspouts Poor 36.0 160 LF

Red paint on metal roofing tiles Fair 8.6 4,950 SF

Tan painted wood porch trim, columns, supports, soffit, and facia Poor 39.2 220 SF

Building 10 Beige and red paint on wood lap siding, shingle siding, and tan paint on wood trim

Poor 36.4 4,280 SF

Tan paint on metal gutters and downspouts Poor 10.1 30 LF

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Table 3 Summary of LBP

Component and General Description

Observed Condition

Highest Lead Concentration mg/cm2

Estimated Quantity

Estimated Abatement Cost

Red paint on metal roofing tiles Fair 9.8 4,160 SF

Tan paint on wood soffit and fascia Poor 35.3 920 SF

Tan paint on wood porch trim, columns, railings, supports, stair, and railings Poor 28.6 300 SF

Tan paint on wood lattice skirting Poor 20.7 290 SF

Gray paint on wood doors, door components, and tan paint on wood trim Poor 35.0 6 Doors

Gray and white paint on wood windows, window components, storm windows, and tan paint on wood trim

Poor 26.4 39 Windows

Building 11

Beige and red paint on wood lap siding, shingle siding, and tan paint on wood trim Poor 33.8 4,280 SF

Tan paint on wood porch trim, columns, and supports Poor 35.8 280 SF

Tan paint on metal gutters and downspouts Poor 3.5 64 LF

Gray and white paint on wood windows, window components, and tan paint on wood trim Poor 35.8 47 Windows

12 Storm Windows

Tan paint on wood soffit and fascia Poor 39.0 1,020 SF

Tan paint on wood lattice skirting Poor 22.6 150 SF

Red paint on metal roofing tiles Fair 23.1 4,160 SF

Gray paint on wood doors, door components, and tan paint on wood trim Fair 35.8 4 Doors

Building 12 Beige paint on wood lap siding and tan paint on wood trim Poor 30.6 3,500 SF

Red paint on wood shake siding and tan paint on wood trim Fair 12.4 780 SF

Red paint on metal roofing tiles Fair 25.3 4,160 SF

Gray paint on wood doors, door components, and tan paint on wood trim Fair 23.1 4 Doors

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Table 3 Summary of LBP

Component and General Description

Observed Condition

Highest Lead Concentration mg/cm2

Estimated Quantity

Estimated Abatement Cost

Gray and white paint on wood windows, window components, storm windows, and tan paint on wood trim

Poor 23.1 39 Windows 39 Storm Windows

Tan paint on wood porch trim, columns, and supports Poor 21.1 280 SF

Tan paint on wood lattice Poor 26.6 90 SF

Tan paint on wood soffit and fascia Poor 22.9 1,020 SF

Building 14 Tan paint on metal gutters and downspouts Poor 35.5 40 LF

Beige paint on wood lap siding and tan paint on wood trim Poor 34.6 4,200 SF

Tan paint on wood porch trim, columns, railings, and supports Poor 30.5 150 SF

Gray paint on wood windows, window components, storm windows, and tan paint on wood trim Poor 27.6 14 Windows

Gray paint on wood doors, door components, and tan paint on wood trim Fair 27.6 2 Doors

Tan paint on wood soffit and fascia Poor 31.5 780 SF

Beige paint on metal siding Poor 17.6 60 SF

Red paint on metal roofing tiles Fair 10.1 1,900 SF

Building 30 Beige paint on shed wood lap siding and trim Poor 16.7 720 SF

Beige paint on wood lap siding, shingle siding, red paint on metal siding, and tan paint on wood trim

Poor 34.4 3,420 SF

Tan paint on wood porch trim, columns, railings, stairs and supports Poor 36.7 175 SF

Tan paint on metal gutters and downspouts Poor 29.1 50 LF

Gray paint on wood doors, door components, and tan paint on wood trim Fair 35.0 2 Doors

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Table 3 Summary of LBP

Component and General Description

Observed Condition

Highest Lead Concentration mg/cm2

Estimated Quantity

Estimated Abatement Cost

Gray paint on wood windows, window components, storm windows, and tan paint on wood trim Poor 27.8 20 Windows

3 Storm Windows

Tan paint on wood soffit and fascia Poor 25.5 625 SF

Red paint on metal roofing tiles Fair 17.8 1,800 SF

Building 31 Beige paint on wood lap siding, shingle siding, red paint on metal siding, and tan paint on wood trim

Poor 33.4 2,630 SF

Tan paint on wood porch trim, columns, railings, and supports Poor 35.3 160 SF

Gray paint on wood porch floor Poor 11.7 260 SF

Gray paint on wood screen door Fair 4.5 1 Door

Gray paint on wood doors, door components, and tan paint on wood trim Fair 28.7 2 Doors

Gray paint on wood windows, window components, and tan paint on wood trim Poor 28.7 17 Windows

Tan paint on metal gutters and downspouts Poor 4.8 40 LF

Red paint on metal roofing tiles Fair 10.1 1,800 SF

Tan paint on wood soffit and fascia Poor 22.0 600 SF

Beige paint on wood ladder Poor 1.7 45 SF

Building 32 Beige paint on wood lap siding, shingle siding, red paint on metal siding, and tan paint on wood trim

Poor 40.5 2,630 SF

Tan paint on wood porch trim, columns, railings, and supports Poor 21.1 150 SF

Tan paint on metal gutters and downspouts Poor 12.5 40 LF

Gray paint on wood doors, door components, and tan paint on wood trim Fair 29.4 2 Doors

Gray paint on wood windows, window components, storm window, and tan paint on wood trim Poor 22.2 18 Windows

1 Storm Window

Red paint on metal roofing tiles Fair 10.1 1,800 SF

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Table 3 Summary of LBP

Component and General Description

Observed Condition

Highest Lead Concentration mg/cm2

Estimated Quantity

Estimated Abatement Cost

Tan paint on wood soffit and fascia Poor 18.9 600 SF

Building 33 Gray paint on wood windows, window components, and tan paint on wood trim

Poor 41.6 15 Windows

Beige paint on wood lap siding, shingle siding, red paint on metal siding, and tan paint on wood trim

Poor 41.6 3,650 SF

Tan paint on wood porch trim, columns, railings, and supports Poor 32.2 160 SF

Gray paint on wood porch floor Poor 4.6 260 SF

Gray paint on wood doors, door components, and tan paint on wood trim Fair 41.6 2 Doors

Red paint on metal roofing tiles Poor 7.9 850 SF

Tan paint on metal gutters and downspouts Poor 13.4 90 LF

Tan paint on wood soffit and facia Poor 32.2 600 SF

Building HS-83 Beige paint on wood lap and shingle siding and white paint on wood trim Fair 30.7 1,800 SF

White paint on wood windows, window components, and trim Fair 16.5 19 Windows

Beige paint on wood soffit and fascia Fair 9.6 530 SF

White paint on wood doors, door components, and trim Fair 16.5 2 Doors

Lead Removal

Design Services

Clearance Services

10% Contingency

TOTAL LBP PROJECT COSTS ESTIMATED

mg/cm2 = milligrams per centimeter squared, SF = Square Feet, LF = Linear Feet, and EA = Each

17 Historical Housing Units National Park Service Mammoth, Yellowstone…