B08_-Section_J-Attachment_11-Regulated_Building_Materials_Survey_Canyon_Village_WWTP_Project.pdf

Regulated Building Materials Survey

Canyon Village Wastewater Treatment Plant Project

Yellowstone National Park, Wyoming

November 30, 2021

Terracon Project No. 24217058

Prepared for:

Jacobs Engineering

Englewood, Colorado

Prepared by:

Terracon Consultants, Inc.

Cheyenne, Wyoming

Terracon Consultants, Inc. 1505 Old Happy Jack Road Cheyenne, WY 82001

P [307] 632-9224 F [307] 637-5756 www.terracon.com

Jacobs Engineering

9191 Jamaica Street

Englewood, Colorado 80112

Attn: Mr. Will Packard, Senior Environmental Planner

P: (307) 575-3341

E: Will Packard@jacobs.com

Re: Regulated Building Materials Survey

Yellowstone National Park – Wastewater Treatment Plant Project

Canyon Village

◼ Headworks Building

◼ AWT Plant

◼ Blower Building

◼ Old Lab Building

◼ Government Lift Station

◼ Brink of the Lower Falls Lift Station

◼ Brink of the Upper Falls Lift Station

◼ Uncle Tom’s Lift Station

Yellowstone, Wyoming 82084

Dear Mr. Packard:

Terracon Consultants, Inc. (Terracon) is pleased to submit the attached Regulated Building

Materials Survey report for the above-referenced site. The purpose of this report is to present the results of the survey performed on October 12 and October 13, 2021. This survey was conducted in general accordance with the Master Services Agreement between Jacobs Engineering Group, Inc. and Terracon Consultants, Inc. dated May 30, 2017, Jacob Engineering’s Statement of Work for Regulated Building Materials Inspection National Park Service associated with Indefinite delivery, indefinite quantity (IDIQ) Contract Number 140P2021D0007, and subcontractor cost estimate submitted to Jacobs Engineering on August 20, 2021. We understand that this survey was requested due planned renovation of the above-referenced buildings.

Terracon appreciates the opportunity to provide this service to Jacobs Engineering. If you have any questions regarding this report, please contact the undersigned at (307) 638-5275.

Sincerely, Terracon Consultants, Inc.

Prepared by: Reviewed by:

Brian K. Ramsell Kevin M. Troyer

Project Manager Senior Industrial Hygienist

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TABLE OF CONTENTS

EXECUTIVE SUMMARY

1.0 INTRODUCTION

1.1 Project Objective

2.0 BUILDING INFORMATION

3.0 FIELD ACTIVITIES

3.1 Asbestos

3.1.1 Inspection Methodology

3.1.2 Visual Assessment

3.1.3 Special Conditions/Observations

3.1.4 Physical Assessment

3.1.5 Sample Collection

3.1.6 Sample Analysis

3.2 Lead Paint

3.2.1 Visual Assessment

3.2.2 Physical Assessment

3.2.3 Sample Collection

3.2.4 Sample Analysis

3.3 Hazardous Building Materials Inventory

3.3.1 Inventory

4.0 REGULATORY OVERVIEW

4.1 Asbestos

4.2 Lead-Containing Paint

4.3 Hazardous Building Materials

5.0 FINDINGS AND RECOMMENDATIONS

5.1 Asbestos

5.1.1 Findings

5.1.2 Recommendations

5.2 Lead Paint

5.3 Hazardous Building Materials

6.0 LIMITATIONS/GENERAL COMMENTS

APPENDIX A ASSUMED ASBESTOS-CONTAINING MATERIALS BY HOMOGENEOUS AREA (HA)

APPENDIX B ASBESTOS SURVEY SAMPLE LOCATION SUMMARY

APPENDIX C LEAD PAINT SURVEY SAMPLE LOCATION SUMMARY

APPENDIX D ANALYTICAL LABORATORY DATA

APPENDIX E DRAWINGS

APPENDIX F PHOTOGRAPHS

APPENDIX G CERTIFICATIONS

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REGULATED BUILDING MATERIALS SURVEY

Yellowstone National Park - Canyon Village WWTP

Yellowstone National Park, Wyoming 82190

EXECUTIVE SUMMARY

Terracon Consultants, Inc. (Terracon) conducted a Regulated Building Materials (RBM) survey of the wastewater treatment plant facilities located in Canyon Village, Yellowstone National Park, Wyoming. The RBM survey included an asbestos survey, lead paint inspection, and an inventory of hazardous building materials. The survey was conducted October 12 and October 13, 2021 in general accordance with the Master Services Agreement between Jacobs Engineering Group, Inc.

and Terracon Consultants, Inc. dated May 30, 2017, Jacob Engineering’s Statement of Work for

Regulated Building Materials Inspection National Park Service associated with Indefinite delivery, indefinite quantity (IDIQ) Contract Number 140P2021D0007, and subcontractor cost estimate submitted to Jacobs Engineering on August 20, 2021.

Asbestos Summary

Terracon understands the asbestos survey was requested due to the planned renovation of the onsite wastewater treatment plant (WWTP) buildings. The asbestos survey was conducted by Mr.

Brian Ramsell, an Asbestos Hazard Emergency Response Act (AHERA)-accredited asbestos inspector and included the interior and exterior of the onsite WWTP buildings listed below. Due to snowfall, roofs were generally excluded from sampling as they could not be safely accessed and/or fully assessed. Samples were delivered to an accredited laboratory for analysis by

Polarized Light Microscopy (PLM).

The Canyon Village onsite WWTP buildings inspected included the following:

◼ Headworks Building (Bldg. 876)

◼ AWT Plant

◼ Blower Building (Bldg. 875)

◼ Old Lab Building

◼ Government Lift Station

◼ Brink of the Lower Falls Lift Station

◼ Brink of the Upper Falls Lift Station

◼ Uncle Tom’s Lift Station

No Asbestos-containing materials (ACMs) were identified as a result of laboratory analysis for the onsite WWTP buildings listed above.

Regulated Building Materials Survey Report

Canyon Village WWTP ■ Yellowstone National Park, Wyoming

November 30, 2021 ■ Terracon Project No. 24217058

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Due to inaccessibility of materials for sampling (pipe flanges could not be opened to access gaskets), the following materials were assumed to be Category I nonfriable ACM under USEPA

NESHAP:

◼ Headworks Building o 07-PM1 - Pipe flange gaskets.

◼ AWT Plant o 08-PM1 - Pipe flange gaskets.

◼ Blower Building o 05-PM1 - Pipe flange gaskets.

◼ Government Lift Station o 05-PM1 - Pipe flange gaskets.

◼ Brink of the Upper Falls Lift Station.

o 02-PM1 - Pipe flange gaskets.

o 02-PM1 - Pipe flange gaskets.

Lead-Containing Paint Summary

The lead paint testing was conducted by Mr. Brian Ramsell on October 12 and October 13, 2021.

Terracon understands the lead paint testing was requested due to the planned renovation of the onsite WWTP buildings.

Representative samples of suspect LP were collected from painted building component substrates of the onsite WWTP buildings. Samples were delivered to an accredited laboratory for analysis by Flame Atomic Absorption Spectrophotometry (AAS).

Detectable quantities of lead were identified in the following painted building components as a result of laboratory analysis:

◼ Government Lift Station o Gray Paint; Interior Concrete Floor o White Paint; Interior CMU Block Walls o White Paint; Metal Door Frames o Brown Paint; Exterior Concrete Eaves o Cream Paint; Exterior Metal Window Frames

◼ Brink of the Lower Falls Lift Station o White Paint; Exterior Concrete Walls

◼ Brink of the Upper Falls Lift Station o White Paint; Exterior Concrete Walls o Brown Paint; Metal Door Frames

Responsive ■ Resourceful ■ Reliable iii o Gray Paint; Metal Door Frames

Lead was not detected in the following painted building components as a result of laboratory analysis:

◼ Headworks Building (Bldg. 876)

◼ Blower Building (Bldg. 875)

◼ Old Lab Building

See Section 5.0 Findings and Recommendations for details.

Hazardous Building Materials Inventory

The following hazardous building materials were observed and inventoried:

o 18 Mercury-Vapor Containing Lamps/Tubes o 1 Fire Extinguisher (Compressed Gas)

◼ AWT Plant o 7 Emergency Lamp Batteries o 1 Emergency Exit and Lamp Battery o 38 Mercury-Vapor Containing Lamps/Tubes o 3 Fire Extinguisher (Compressed Gas) o 1 Self-Luminous Exit Sign (Tritium)

◼ Blower Building o 2 Emergency Lamp Batteries o 20 Mercury-Vapor Containing Lamps/Tubes o 1 Fire Extinguisher (Compressed Gas) o 1 Self-Luminous Exit Sign (Tritium)

◼ Old Lab Building o 4 Mercury-Vapor Containing Lamps/Tubes o 1 Smoke Detector

◼ Brink of the Lower Falls Lift Station o 10 Mercury-Vapor Containing Lamps/Tubes

◼ Brink of the Upper Falls Lift Station o 1 Emergency Lamp Battery

◼ Uncle Toms’ Lift Station o 6 Mercury-Vapor Containing Lamps/Tubes

There were no hazardous building materials observed for the onsite Government Lift Station.

See Section 5.0 Findings and Recommendations for details.

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REGULATED BUILDING MATERIALS SURVEY

Yellowstone National Park - Canyon Village WWTP

Yellowstone National Park, Wyoming 82190

1.0 INTRODUCTION

Terracon Consultants, Inc. (Terracon) conducted a Regulated Building Materials (RBM) survey of the wastewater treatment plant facilities located in Canyon Village, Yellowstone National Park, Wyoming. The RBM survey included an asbestos survey, lead paint inspection, and an inventory of hazardous building materials. The survey was conducted October 12 and October 13, 2021 in general accordance with the Master Services Agreement between Jacobs Engineering Group, Inc.

and Terracon Consultants, Inc. dated May 30, 2017, Jacob Engineering’s Statement of Work for

Regulated Building Materials Inspection National Park Service associated with Indefinite delivery, indefinite quantity (IDIQ) Contract Number 140P2021D0007, and subcontractor cost estimate submitted to Jacobs Engineering on August 20, 2021.

1.1 Project Objective

The RBM survey included the interior and exterior of the following onsite WWTP buildings:

◼ Blower Building

◼ Old Lab Building

◼ Government Lift Station

◼ Brink of the Lower Falls Lift Station

◼ Brink of the Upper Falls Lift Station

The roofs of the buildings above were to be included in the survey; however, the roofs were generally excluded from sampling as they could not be safely accessed and/or fully assessed due to snowfall.

The asbestos survey was conducted to satisfy the requirements of the United States

Environmental Protection Agency (USEPA) 40 Code of Federal Regulations (CFR) Part 61

National Emission Standards for Hazardous Air Pollutants (NESHAP), Subpart M. At the client’s request, the asbestos survey did not include the roof. The survey did not include destructive investigation to inspect wall cavities or other concealed areas. The asbestos survey was conducted October 12 and October 13, 2021 by an AHERA1-accredited asbestos inspector in accordance the sampling protocols established in USEPA 40 CFR Part 763-Asbestos, Subpart

E-Asbestos-Containing Materials in Schools (known as AHERA).

1 Asbestos Hazard Emergency Response Act

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The LP inspection was conducted to provide information for compliance with United States

Occupational Health and Safety Administration (USOSHA) 29 CFR 1910.1025 Lead and 29 CFR

1926.62 Lead. The LCP survey not intended to meet the requirements of the U.S. Department of

Housing and Urban Development (HUD) Guidelines for the Evaluation and Control of Lead-Based

Paint (LBP) Hazards in Housing or the USEPA Resource Conservation and Recovery Act (RCRA) for waste determination. The LP inspection was performed on October 25, 2021 utilizing the testing and sampling protocols established in the HUD Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing, Chapter 7 (2012 revision) for paint chip sampling.

The hazardous building materials (HBM) inventory included universal wastes and other hazardous building materials, such as polychlorinated biphenyls (PCB) in light ballasts and transformers; chlorofluorocarbons (CFCs); equipment potentially containing heavy metals, smoke detectors containing radioactive material; paints, solvents, chemicals, herbicides, and compressed gas. HBMs in the building are required to be properly disposed of or recycled prior to renovation or demolition in accordance with USEPA Resource Conservation and Recovery Act

(RCRA) and USEPA Toxic Substances Control Act (TSCA).

2.0 BUILDING INFORMATION

Canyon Village WWTP was constructed in the 1990’s as a 0.5 million gallon per day (MGD) facility. The facility consists of eight (8) structures; a headworks building, plant process building, blower building, old lab building, and four lift stations.

◼ The Headworks Building (Building 876) is an approximately 289 square-foot concrete and concrete masonry unit (CMU) block structure with a gabled metal roof.

◼ The Advanced Waste Treatment (AWT) Plant is an approximately 5,365 square-foot concrete and concrete masonry unit (CMU) block structure with a gabled metal roof.

◼ The Blower Building (Building 875) is an approximately 2,828 square-foot concrete masonry unit (CMU) block structure with slab-on-grade foundation and combination hip and gabled metal roof. The building was constructed prior to the 1990’s however the actual construction date was not provided.

◼ The Old Lab Building is an approximately 287 square-foot wood-framed structure with slab-on-grade foundation, wood panel siding, and gabled metal roof. The building was constructed prior to the 1990’s however the actual construction date was not provided.

◼ The Government Lift Station is an approximately 154 square-foot concrete structure with a flat, concrete roof. The building was constructed prior to the 1990’s however the actual construction date was not provided.

◼ The Brink of the Lower Falls Lift Station is an approximately 234 square-foot wood-framed structure with concrete basement foundation and gabled metal roof. The building was constructed in the 1970’s.

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◼ Brink of the Upper Falls Lift Station is an approximately 387 square-foot wood-framed structure with concrete basement foundation and gabled metal roof. The building was constructed in the 1970’s.

◼ Uncle Tom’s Lift Station is an approximately 294 square-foot wood-framed structure with concrete basement foundation and gabled metal roof. The building was constructed in the

1970’s.

3.0 FIELD ACTIVITIES

3.1 Asbestos

The asbestos survey was conducted on October 12 and 13, 2021 by Mr. Brian Ramsell, an

AHERA-accredited asbestos building inspector. A copy of the asbestos inspector’s certification is provided in Appendix G. A summary of survey activities is provided below.

3.1.1 Inspection Methodology

The survey was conducted in general accordance with the sample collection protocols established in USEPA regulation 40 CFR 763, the Asbestos Hazard Emergency Response Act (AHERA).

The scope of the asbestos inspection was to identify ACM in the onsite WWTP buildings which are planned for renovation. A material is considered to be ACM if the asbestos content is greater than 1% asbestos. The inspection included the following steps:

◼ Visual inspections of the structures and identification of suspect homogeneous and non-homogeneous ACM that could be disturbed during demolition.

◼ Determination of friability by touching all identified suspect ACM.

◼ Development of a sampling plan for each material based on the homogeneous area, material type, friability, accessibility and material locations. Homogeneous and non-homogeneous material samples were submitted for laboratory analysis by Polarized Light

Microscopy (PLM).

◼ Comprehensive inspection for materials in the structures that will be impacted during demolition.

A homogeneous area (material) is defined as an area containing a material that appears similar throughout with regard to color, texture, and date of application. Materials that were inspected, but not suspected to contain asbestos, are not included in this report. Such materials include concrete, stone, ceramic tiles, carpet, fiberglass, mineral/rock wool, plastic, glass, rubber, and wood products.

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Each type of suspect building material was assigned a unique identification code. Each sample was identified by homogenous area (HA) number, alphanumeric material code, and the sample number. For example, if 2' x 4' lay-in ceiling panels are sampled, the sample nomenclature starts with the HA number 01 (the first type of material sampled), then the alphanumeric material code

CT4 (code for 2' x 4' lay-in ceiling panels), followed by the sample number 01 (the first sample collected). The completed nomenclature appears as 01-CT4-01 (followed by subsequent samples, 01-CT4-02, 01-CT4-03...). Material size, thickness, substrate, material friability, location, and quantity were recorded.

Each material was classified into one of three available types of material descriptions.

◼ Surfacing Material refers to a wide range of trowel or spray-applied materials typically used for acoustical or fire-retardant purposes. Examples include spray-applied fire retardants and acoustical texture ceilings.

◼ Thermal System Insulation (TSI) refers to insulation that is applied to heating or mechanical system components. Examples include pipe, tank and boiler insulation.

◼ Miscellaneous Materials refers to all other materials that do not fall into one of the above categories. Examples include floor tile, adhesives, and ceiling tiles.

Once the material classification was determined, the inspector then determined the friability of the material. The USEPA distinguishes between friable and non-friable forms of ACMs. Friable materials can be crumbled or reduced to powder by hand pressure, whereas non-friable materials cannot. Friable materials are more likely to release fibers into the air, especially during renovation and demolition activities. Therefore, the distinction between friable and non-friable materials is important.

USEPA have identified two categories of materials, Regulated Asbestos-Containing Materials

(RACM) and Non-Friable ACM, for the purpose of identifying materials that can or cannot remain in a building during demolition.

• RACM are defined as friable materials, and non-friable materials that have a high probability of becoming friable during demolition activities. RACM are categorized as all friable ACM, Category I non-friable ACM that may become friable (subject to sanding, grinding, cutting or abrading during the demolition process), or Category II non-friable

ACM that has a probability of becoming crumbled, pulverized, or reduced to a powder by the force expected to act on the material in the course of normal demolition operations

(that are performed in accordance with USEPA NESHAP demolition guidance).

• Non-regulated asbestos-containing materials (non-RACM) are those non-friable materials likely to remain non-friable during normal demolition operations. Non-RACMs are categorized as either Category I non-friable ACM that will not be subject to sanding, grinding, cutting or abrading during the demolition process, or Category II non-friable ACM

Responsive ■ Resourceful ■ Reliable 5 that has a low probability of becoming crumbled, pulverized, or reduced to a powder by the force expected to act on the material in the course of normal demolition operations.

USEPA regulations require proper removal and disposal of all RACM and non-RACM prior to renovation operations.

The following Bulk Sampling protocol for friable and Category I and II non-friable materials was used to determine the number of samples to be collected for friable materials and non-friable materials deemed potential RACM (non-friable materials with potential to be rendered friable during normal demolition).

Table #1 - Bulk Sampling Strategy

Material Homogeneous

Area

Units Minimum

Number of

Samples

Friable Surfacing Less than 1000

1000 to 5000

More than 5000

SF 3

Friable and Non-Friable Thermal System

Insulation

LF / SF / EA 3

Friable and Non-Friable Miscellaneous Materials LF / SF / EA 3

Suspect building materials that are considered surfacing are collected in a statistically random manner using a random number generator.

3.1.2 Visual Assessment

Survey activities were initiated with visual observation of the interior and exterior of the building to identify homogeneous areas of suspect ACM. A homogeneous area (HA) consists of building materials that appear similar throughout in terms of color and texture with consideration given to the date of application. Interior and exterior assessments were conducted in visually accessible areas of the building proposed for demolition. Building materials identified as concrete, glass, wood, fiberglass, mineral/rock wool, masonry, metal or rubber were not considered suspect ACM.

A total of 29 homogeneous areas of suspect ACM were identified at the Canyon Village onsite

WWTP buildings; six (6) at the Headworks Building; seven (7) at the AWT Plant; four (4) at the

Blower Building; five (5) at the Old Lab Building; four (4) at the Government Lift Station (LS); one

(1) at the Brink of the Lower Falls LS; one (1) at the Brink of the Upper Falls LS; and one (1) at

Uncle Tom’s LS.

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3.1.3 Special Conditions/Observations

The inspector made the following observations during the survey:

◼ The vicinity of Canyon Village received up to 8-inches of snow the day prior to the survey which did not allow for inspection and assessment of the roofs of the onsite WWTP buildings. The roofs should be inspected by an AHERA-accredited asbestos inspector prior to any work that will disturb roofing materials.

◼ Pipe flanges were observed at the Canyon Village onsite WWTP buildings, except at the

Old Lab Building. Gaskets within the pipe flanges were not accessible and were assumed by the inspector to be ACM with exception to the pipe gaskets at the Brink of the Lower Falls

Lift Station which were visible and accessible red rubber gaskets and not considered to be suspect ACM.

3.1.4 Physical Assessment

A physical assessment of each HA of suspect ACM was conducted to assess the friability and condition of the materials. A friable material is defined by the USEPA as a material which can be crumbled, pulverized, or reduced to powder by hand pressure when dry. Friability was assessed by physically touching suspect materials.

3.1.5 Sample Collection

Based on results of the visual observation, bulk samples of suspect ACM were collected in general accordance with USEPA AHERA sampling protocols. Samples of suspect materials were collected from randomly selected locations in each homogeneous area. Bulk samples were collected using wet methods as applicable to reduce the potential for fiber release. Samples were placed in sealable containers and labeled with unique sample numbers using an indelible marker.

Although reasonable effort was made to survey accessible suspect materials, additional suspect but un-sampled materials could be located inside walls, voids, or in other concealed areas.

As part of the inspection, bulk samples of each suspect material were collected by accredited asbestos inspectors in a random and representative manner as determined by each inspector.

Samples were collected by taking a core sample that included all layers within the suspect material. Samples from soft friable materials were obtained by removing a small portion using wetting techniques. All samples were placed in sealable containers and labeled with unique sample numbers using an indelible marker. Digital photographs were also collected to provide a visual reference for each material.

Each type of suspect building material was assigned a unique identification code. Each sample was identified by homogenous area (HA) number, alphanumeric material code, and the sample

Responsive ■ Resourceful ■ Reliable 7 number. For example, if 2' x 4' lay-in ceiling panels are sampled, the sample nomenclature starts with the HA number 01 (the first type of material sampled), then the alphanumeric material code

CT4 (code for 2' x 4' lay-in ceiling panels), followed by the sample number 01 (the first sample collected). The completed nomenclature appears as 01-CT4-01 (followed by subsequent samples, 01-CT4-02, 01-CT4-03...). Material size, thickness, substrate, material friability, location, and quantity were recorded in the Sample Log.

Terracon collected 92 bulk samples from 29 homogeneous areas of suspect ACM at the Canyon

Village onsite WWTP buildings; 18 from the Headworks Building; 21 from the AWT Plant; 12 from the Blower Building; 17 from the Old Lab Building; 12 from the Government Lift Station (LS); three

(3) from the Brink of the Lower Falls LS; three (3) from the Brink of the Upper Falls LS; and three

(3) from at Uncle Tom’s LS.

A summary of suspect ACM samples collected during the survey is provided in Appendix B. A drawing containing the sample locations of suspect ACM is provided in Appendix E. Photographs of suspect ACM are provided in Appendix F.

3.1.6 Sample Analysis

Asbestos bulk samples were submitted under chain of custody to Eurofins EMLab P&K of Denver, Colorado, for analysis by polarized light microscopy (PLM) with dispersion staining techniques per USEPA methodology 600/R-93/116. Analysis of the bulk samples was conducted in accordance with Appendix E to Subpart E of 40 CFR Part 763 and EPA/600/R-93/116. The percentage of asbestos, where applicable, was determined by microscopic visual estimation.

Aerotech Laboratories, Inc is accredited under the National Voluntary Laboratory Accreditation

Program (NVLAP) Accreditation No. 500053-0.

Analysis of the bulk samples was performed using PLM using procedures developed by McCrone

Research Institute, and in compliance with the guidelines established by the USEPA (EPA-

600/R93/116 and M4-82-020, Dec. 1982) to determine asbestos type and content. The PLM samples are reported as percent asbestos by weight. Percent asbestos for separate layers and total for the sample are delineated in the laboratory report.

As of November 90, 1990, the USEPA NESHAP requires that samples of friable material with less than 10 percent asbestos be analyzed by the point-count procedure or must be assumed positive for asbestos.

Copies of the laboratory analytical reports and chain-of-custodies are provided in Appendix D.

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3.2 Lead Paint

The LP inspection was conducted on October 12 and October 13, 2021 by Mr. Brian Ramsell utilizing the testing protocols established in the HUD Guidelines for the Evaluation and Control of

Lead-Based Paint Hazards in Housing, Chapter 7 (2012 revision). The LP inspection was conducted to provide information for compliance with United States Occupational Health and

Safety Administration (USOSHA) 29 CFR 1910.1025 Lead and 29 CFR 1926.62 Lead. The LCP survey not intended to meet the requirements of the U.S. Department of Housing and Urban

Development (HUD) Guidelines for the Evaluation and Control of Lead-Based Paint (LBP)

Hazards in Housing or the USEPA Resource Conservation and Recovery Act (RCRA) for waste determination. A summary of inspection activities is provided below.

3.2.1 Visual Assessment

Terracon visually assessed the interior and exterior of the site buildings to identify painted/coated building components suspected of containing lead. Painted/coated surfaces which appeared similar throughout in terms of color, texture, substrate and date of application are treated as a homogeneous material for paint chip collection purposes. Painted/coated surfaces were visually assessed for evidence of distress such as chipping, cracking, flaking, and/or peeling.

3.2.2 Physical Assessment

A physical assessment of each selected painted surface was conducted to assess its condition.

The painted surfaces were assessed as good, fair or poor condition depending on degree of distress such as chipping, cracking, flaking, and/or peeling.

3.2.3 Sample Collection

Based on the results of the visual observation, representative paint chip samples of painted substrates were collected from the interior and/or exterior surfaces of the subject buildings. Samples were placed in sealable containers and labeled with unique sample numbers using an indelible marker.

Terracon collected 29 representative paint chip samples the Canyon Village WWTP onsite buildings; three (3) from the Headworks Building; five (5) from the AWT Plant; three (3) from the

Blower Building; three (3) from the Old Lab Building; five (5) from the Government Lift Station

(LS); three (3) from the Brink of the Lower Falls LS; three (3) from the Brink of the Upper Falls

LS; and four (4) from at Uncle Tom’s LS. The LCP sample location summary is provided in

Appendix C.

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3.2.4 Sample Analysis

Samples of suspect LCP were delivered under proper chain-of-custody to EMSL Analytical, Inc.

(EMSL) of Indianapolis, Indiana for analysis using Atomic Absorption Spectrophotometry

(AAS)/Atomic Emission Spectroscopy-Inductively Coupled Plasma (AES-ICP) USEPA Method

SW846 3050B/7000B. EMSL is accredited under the American Industrial Hygiene Association

(AIHA) Environmental Lead Laboratory Accreditation Program (ELLAP) program (Lab ID 157245).

Copies of the analytical report and chain-of-custody form are provided in Appendix D.

3.3 Hazardous Building Materials Inventory

The hazardous building materials (HBM) inventory was conducted October 12 and October 13, 2021 by Mr. Brian Ramsell. The HBM inventory was performed to provide information for hazardous materials covered under the USEPA Resource Conservation and Recovery Act

(RCRA) and Toxic Substances Control Act (TSCA).

3.3.1 Inventory

The HBM inventory consisted of locating the following suspect devices or equipment: Locations of devices or equipment were inventoried, and labels checked where applicable. Devices or equipment that did not have accessible labeling, other than light fixtures, were not opened.

Battery-containing devices (e.g., certain lead-acid batteries not recycled under other regulations;

button silver-oxide and zinc-air; and 9-volt, C, AA, coin, and button rechargeable lithium);

Pesticides;

Mercury-containing devices (e.g., thermostats, switches);

Mercury-containing devices/electric lamps (e.g., fluorescent, high intensity discharge, sodium vapor, and mercury vapor).

PCB-containing equipment (e.g. electrical transformers, large electrical capacitors and electrical light ballasts);

CFC-containing equipment (e.g. refrigeration and air-conditioning equipment)

Smoke detectors (e.g. photoelectric or ionizing detectors. The ionizing variety contains a small amount of radioactive material (americium-241); and

Tritium exit signs.

Terracon identified 113 HBMs at the Canyon Village onsite WWTP building. HBMs were not identified at the Government Lift Station. The HBM inventory summary is provided in Section 5.5.

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4.0 REGULATORY OVERVIEW

4.1 Asbestos

The asbestos NESHAP (40 CFR Part 61, Subpart M) regulates asbestos fiber emissions and asbestos waste disposal practices. The asbestos NESHAP regulation also requires the identification and classification of existing ACM according to friability prior to demolition or renovation activity. Friable ACM is a material containing more than 1% asbestos that, when dry, can be crumbled, pulverized or reduced to powder by hand pressure. Friable ACMs are considered RACM.

The asbestos NESHAP regulation classifies ACM as RACM, Category I nonfriable ACM or

Category II nonfriable ACM. RACM includes all friable ACMs, along with Category I and Category

II nonfriable ACMs that have become friable; will be or have been subjected to sanding, grinding, cutting or abrading; or have a high probability of becoming or have become crumbled, pulverized, or reduced to powder in the course of renovation or demolition activity. Category I nonfriable ACM are exclusively asbestos-containing packings, gaskets, resilient floor coverings, resilient floor covering mastics and asphalt roofing products that contain more than 1% asbestos. Category II nonfriable ACM are all other nonfriable materials other than Category I nonfriable ACM that contain more than 1% asbestos. Category II nonfriable ACM generally includes but is not limited to cementitious material such as: cement pipes, cement siding, cement panels, glazing, mortar and grouts.

The Wyoming Department of Environmental Quality (WDEQ), enforces the Asbestos NESHAP as adopted by reference under authority of Sections 35-11-110, 112, 114, and 202 through 212 of the Wyoming Environmental Quality Act, 1993 and in accordance with provisions of Sections

16-3-101 through 16-3-115 of the Wyoming Administrative Procedures Act. The owner or operator must provide WDEQ with written notification at least 10 working days prior to the commencement of asbestos abatement activities that will disturb RACM in amounts greater than or equal to 160 square feet, 260 linear feet or 35 cubic feet.

The USOSHA asbestos standard for construction (29 CFR 1926.1101) regulates workplace exposure to asbestos. The USOSHA standard requires that employee exposure to airborne asbestos fibers be maintained below the permissible exposure limits (PELs) of 0.1 asbestos fiber per cubic centimeter of air (0.1 f/cc) as an 8-hour time-weighted average (TWA) or 1.0 f/cc as a 30-minute excursion limit. The USOSHA standard classifies construction and maintenance activities that could disturb ACM and specifies work practices and precautions that employers must follow when engaging in each class of regulated work.

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4.2 Lead-Containing Paint

The LCP sampling was performed in general accordance with the procedures prescribed in the

USEPA’s work practice standards for conducting lead paint testing (40 CFR 745.227). Lead is regulated by the USEPA and USOSHA.

The Resource Conservation and Recovery Act (RCRA) gave the USEPA authority to regulate the waste status of demolition and renovation debris, including lead-containing materials. Specific notification and testing requirements must be addressed prior to transporting, treating, storing, or disposing of hazardous wastes. Lead-containing wastes are considered hazardous waste under

RCRA if Toxicity Characteristic Leaching Procedure (TCLP) results exceed 5 milligrams per liter

(mg/L). USEPA exempts from most RCRA requirements those generators whose combined hazardous waste generation is less than 100 kilograms (kg) per month.

Detectable lead quantities may constitute a lead dust hazard during renovation/demolition activities.

Personnel performing renovation/demolition activities that may disturb painted components with concentrations of lead above the designated analytical detection limit should comply with all current

USOSHA regulations in order to minimize employee exposure. USOSHA regulates construction activities that disturb lead-containing material regardless of the concentration. Currently, any proposed renovation/demolition is subject to the USOSHA regulations (29 CFR 1926.62 – Lead

Exposure in Construction).

Contractors and employers are required to comply with 29 CFR 1926.62. Construction work covered by USOSHA standards includes any repair or renovation activities or other activities that disturb in-place lead-containing materials but does not include routine cleaning and repainting where there is insignificant damage, wear, or corrosion of existing lead-containing coatings or substrates. Employers must assure that no employee will be exposed to lead at concentrations greater than 50 micrograms per cubic meter (g/m3) averaged over an eight-hour period without adequate protection. The USOSHA Standards also establish an action level of 30 g/m3, which if exceeded, triggers the requirement for medical monitoring. The USOSHA standard does not define the amount of lead in paint that constitutes lead-containing paint. A negative exposure assessment per trigger task should be conducted to determine if actual airborne levels are below the required

USOSHA action and permissible levels.

4.3 Hazardous Building Materials

Universal Waste

USEPA’s universal waste regulations are found in 40 CFR 273 Universal Wastes. The State of

Wyoming has adopted 40 CFR 273 and does not recognize universal wastes other than those set forth by the USEPA. The universal waste regulation streamlines the hazardous waste management standards for certain categories of hazardous waste that are commonly generated

Responsive ■ Resourceful ■ Reliable 12 by a wide variety of establishments. The universal waste regulations apply to four types of universal waste:

Batteries (40 CFR 273.2)

Pesticides (40 CFR 273.3)

Mercury-containing equipment (40 CFR 273.4)

Mercury lamps/tubes (40 CFR 273.5)

The standard helps the promote the collection and recycling of universal waste, ease the regulatory burden on retail stores and other generators that wish to collect these wastes, ease the regulatory burden on transporters of these wastes, and encourage the development of municipal and commercial programs to reduce the quantity of these wastes going to municipal solid waste landfills or combustors.

Four types of regulated participants are defined in the universal waste system: small quantity handlers, large quantity handlers, universal waste transporters and universal waste destination facilities.

In general, materials managed as universal waste can be stored for a year and are not required to be shipped with a manifest. In addition, universal waste does not need to be counted for the purpose of determining whether the generator is conditionally exempt small quantity, small quantity, or large quantity. The universal waste regulations do require that the materials be managed in a way to prevent releases to the environment and tailors those requirements to each type of universal waste (for small quantity handlers and for large quantity handlers). Finally, the standards also include labeling, a requirement to respond to releases, and transport to a facility that is permitted or otherwise designated for receiving hazardous waste, like a recycler.

Polychlorinated Biphenyls

USEPA regulation 40 CFR 761, Subpart R regulates disposal of PCB bulk product waste under section 761.62. Small ballasts containing less than 50 parts per million (ppm) PCBs may be disposed of at a solid waste landfill. However, the effort to determine the PCB content in ballasts is burdensome, and the USEPA recommends that all PCB ballasts be disposed of at a TSCA-approved incinerator facility. It should be noted that ballasts manufactured after 1978 do not typically contain

PCBs and “No PCBs” will be stated on labels affixed to these ballasts. If no indication is made on the ballast label, the ballast should be assumed to contain PCBs.

Chlorofluorocarbons (CFC)

USEPA regulations 40 CFR 82, Subpart F under Section 608 of the Clean Air Act include requirements for the safe disposal of refrigeration and air-conditioning equipment. These

Responsive ■ Resourceful ■ Reliable 13 requirements are designed to minimize refrigerant emissions when these appliances are disposed. CFCs are not considered a hazardous waste if reclaimed.

Smoke Detectors

Smoke detectors can be one of two kinds: photoelectric or ionizing. The ionizing variety contains a small amount of radioactive material (americium-241).

Specific requirements do not exist for the disposal of smoke detection devices. USEPA’s

Household Hazardous Waste program encourages waste reduction and minimization but does not exert any special disposal requirements. Many manufacturers encourage return of the devices to their facilities for salvage and recycling of components.

Tritium Exit Signs

Exit signs that glow in the dark (without need of an external energy source such as electricity) often contain a radioactive gas called tritium. Tritium exit signs pose little or no threat to public health and safety and do not constitute a security risk. Tritium is regulated by the United States

Nuclear Regulatory Commission (USNRC) 10 CFR 31.5.

USNRC requires proper accounting and disposal of all radioactive materials. Proper handling and accounting are important, because a damaged or broken sign could cause mild radioactive contamination of the immediate vicinity, requiring a potentially expensive clean up.

5.0 FINDINGS AND RECOMMENDATIONS

5.1 Asbestos

5.1.1 Findings

No ACMs were identified as a result of laboratory analysis for the Canyon Village onsite

WWTP buildings.

The following materials were assumed to be Category I nonfriable ACM under USEPA NESHAP:

o 07-PM1 - Pipe flange gaskets.

◼ AWT Plant o 08-PM1 - Pipe flange gaskets.

◼ Blower Building o 05-PM1 - Pipe flange gaskets.

◼ Government Lift Station

Responsive ■ Resourceful ■ Reliable 14 o 05-PM1 - Pipe flange gaskets.

◼ Brink of the Upper Falls Lift Station.

o 02-PM1 - Pipe flange gaskets.

o 02-PM1 - Pipe flange gaskets.

5.1.2 Recommendations

According USEPA NESHAP regulations, Category I nonfriable ACM that has become friable or that will be or has been subjected to sanding, grinding, cutting, or abrading, is considered RACM and is required to be removed prior to disturbance by any renovation or demolition activities.

Additionally, in the case of demolition, Category I nonfriable ACM need not be removed unless demolition activities will involve intentional scraping, burning, grinding, mechanically chipping, drilling, sand or bead blasting, explosive demolition or other methods that could mechanically powder the material or otherwise render it friable.

USOSHA asbestos standard for construction (29 CFR 1926.1101) regulates workplace exposure to asbestos regardless of concentration. The disturbance of materials containing asbestos has the potential to result in the release of airborne asbestos fibers. The USOSHA standard requires that employee exposure to airborne asbestos fibers be maintained below 0.1 asbestos fibers per cubic centimeter of air (0.1 f/cc). Employers whose workers may be exposed to asbestos greater than the permissible exposure limits (PEL) must comply with USOSHA’s Hazard Communication standard, which includes training, medical surveillance, and respiratory protection (as required by

USOSHA 29 CFR 1910.134). An employer may demonstrate that employee exposure during an operation is expected to be consistently below the PEL by conducting an initial negative exposure assessment (NEA).

Disturbance or removal of materials containing asbestos must, at a minimum, follow the methods of compliance. Disturbance or removal of materials containing greater than 1% asbestos must be conducted under the appropriate class of work (Class I, Class II, or Class III work) as defined in the USOSHA standard. Removal of the gaskets would be a Class II job or Class III job if conducted for a maintenance activity.

Removal of ACM must be conducted by an asbestos abatement contractor with AHERA-accredited asbestos abatement workers under supervision of an AHERA-accredited asbestos abatement contractor/supervisor and in accordance with applicable local, state, and federal regulations.

Asbestos abatement contractors should be contacted to obtain competitive bids for removal of

ACM.

A 10-working day Notification of Demolition and Renovation Form is required to be turned in to

WDEQ prior to the start of any renovation that will create or disturb any amount of RACM and/or nonfriable ACM and for every demolition project regardless if asbestos is present or not. A copy

Responsive ■ Resourceful ■ Reliable 15 of the most current demolition notification form approved by WDEQ can be found at https://deq.wyoming.gov/air-quality/compliance/asbestos/.

Asbestos-containing waste materials must be handled and transported to a landfill permitted to accept asbestos related waste for proper disposal. Landfill should be contacted in advance to confirm acceptance and other requirements.

The roofs of the Canyon Village onsite WWTP buildings, except for the Headwork Buildings, were not inspected, assessed, or sampled due to snow on the roof. Roofing materials should be assumed to be ACM unless sampling is conducted by an AHERA-accredited asbestos inspector in accordance with state and federal regulations and samples analyzed by a NVLAP-accredited laboratory.

Terracon made reasonable efforts to sample suspect materials in the building. If suspicious materials are encountered during renovation activities that do not appear to have been characterized as ACM or non-ACM, these materials must be assumed to be ACM until samples are collected by an AHERA-accredited asbestos inspector and analyzed by an NVLAP-accredited laboratory to prove otherwise. If the building or portion thereof will be demolished, an additional destructive investigation by an AHERA-accredited asbestos inspector must be conducted for wall cavities or other concealed areas.

A summary of the locations, conditions, and approximate quantities of assumed ACM are provided in Appendix A. The summary of sample locations and laboratory report are provided in Appendix

B.

5.2 Lead Paint

Lead paint (LP) was identified at the four (4) of the eight (8) Canyon Village onsite WWTP buildings.

The following LPs were identified as a result of laboratory analysis:

Government Lift Station

Sample

Number Location Component Substrate Color Condition

Result

(% by weight)

P01 Interior Floor Concrete Gray Intact 0.56 %

P02 Interior Wall CMU Block White Intact 0.19 %

P03 Interior Door Frame Metal White Intact 3.3 %

P04 Exterior Eave Concrete Brown Fair 0.041 %

P05 Exterior Window Frame Metal Cream Intact 12 %

Responsive ■ Resourceful ■ Reliable 16

Intact No visible damage or deterioration Fair Less than or equal to 10% of the total surface area of the component is deteriorated Poor More than 10% of the total surface area of the component is deteriorated

Brink of the Lower Falls Lift Station

Number Location Component Substrate Color Condition

Result

(% by weight)

P02 Interior Wall Concrete White Intact 0.020 %

Brink of the Upper Falls Lift Station

Number Location Component Substrate Color Condition

Result

(% by weight)

P02 Interior Wall Concrete White Intact 0.018 %

P03 Interior Door Frame Metal Brown Intact 0.095 %

Uncle Tom’s Lift Station

Number Location Component Substrate Color Condition

Result

P03 Interior Door Frame Metal Gray Intact 0.049 %

Contractors disturbing LPs are required to comply with USOSHA 29 CFR 1926.62. Lead wastes must be recycled or disposed of properly in accordance with federal, state or local regulations.

Terracon can assist with waste characterization of lead-containing paints for compliance with

Resource Recovery and Conservation Act (RCRA) through sampling of those materials coated with paints containing greater than 0.01% lead and submission of those samples for analysis via the Toxicity Characteristic Leaching Procedure (TCLP).

Analysis of the remaining paint chip samples collected from the Canyon Village onsite WWTP buildings yielded results below the laboratory reporting limit. Paint that is below the laboratory reporting limit is not regulated.

The summary of sample locations is provided in Appendix C. Copies of the laboratory analytical reports and chain-of-custodies are provided in Appendix D.

5.3 Hazardous Building Materials

A cursory inspection was conducted the Canyon Village onsite WWTP buildings. Hazardous building materials observed during inventory are listed in the table below:

Universal Waste Headworks

Building AWT Plant

Blower

Building Old Lab

Batteries Emergency Lamps None Observed 7 2 None Observed

Batteries Other None Observed 1 None Observed None Observed

Responsive ■ Resourceful ■ Reliable 17

Liquid Mercury-Containing Equipment None Observed None Observed None Observed None Observed

Mercury-Vapor Containing

Lamps/Tubes 18 38 20 4

Pesticides None Observed None Observed None Observed None Observed

Universal Waste Government

Lift Station

Brink of Lower

Falls LS

Brink of Upper

Falls LS

Uncle Tom’s

Lift Station

Batteries Emergency Lamps None Observed None Observed 1 None Observed

Batteries Other None Observed None Observed None Observed None Observed

Liquid Mercury-Containing Equipment None Observed None Observed None Observed None Observed

Mercury-Vapor Containing

Lamps/Tubes None Observed 10 None Observed 6

Pesticides None Observed None Observed None Observed None Observed

Hazardous Building Materials &

Other Concerns

Headworks

Building AWT Plant

Blower

Building Old Lab

PCB-containing Light Ballasts &

Transformers None Observed None Observed None Observed None Observed

Compressed Gas (Fire Extinguishers and Suppression System(s)) 1 3 1 None Observed

CFC-Containing Equipment None Observed None Observed None Observed None Observed

Smoke Detectors None Observed None Observed None Observed 1

Tritium Signs None Observed 1 1 None Observed

Hazardous Building Materials &

Other Concerns

Government

Lift Station

Brink of Lower

Falls LS

Brink of Upper

Falls LS

Uncle Tom’s

Lift Station

PCB-containing Light Ballasts &

Transformers None Observed None Observed None Observed None Observed

Compressed Gas (Fire Extinguishers and Suppression System(s)) None Observed None Observed None Observed None Observed

CFC-Containing Equipment None Observed None Observed None Observed None Observed

Smoke Detectors None Observed None Observed None Observed None Observed

Tritium Signs None Observed None Observed None Observed None Observed

The HBM inventory was limited to visual observations of readily accessible areas and providing an inventory of recognizable hazardous building materials. Sampling of HBMs was not included in the scope-of work.

Hazardous building materials were not observed at the Government Lift Station.

Responsive ■ Resourceful ■ Reliable 18

Batteries

The following equipment was observed to be battery-backed:

◼ 10 Emergency lights o Seven (7) at the AWT Plant; two (2) at the Blower Building; and one (1) at the Brink of the Lower Falls LS.

◼ One (1) Exit sign o One (1) at the AWT Plant.

Terracon recommends that batteries be managed in compliance with the 40 CFR 273.2 of the universal waste regulation.

Mercury

The following were observed to potentially be mercury-containing:

Mercury Liquid-Containing Equipment:

Mercury liquid-containing equipment was not observed at the Canyon Village onsite WWTP buildings.

Mercury Vapor-Containing Lamps/Tubes:

◼ 96 fluorescent lamps/tubes o 18 at the Headworks Building; 38 at the AWT Plant; 20 at the Blower Building; four (4) at the Old Lab Building; 10 at the Brink of the Lower Falls LS, and two (2) at Uncle

Tom’s LS.

According to USEPA, disposal of mercury-containing fluorescent lamps (tubes) is federally regulated under the Resource Conservation and Recovery Act (RCRA). Because of the high cost of testing a fluorescent lamp for mercury and the likelihood that the lamp will fail the test, USEPA recommends assuming that all fluorescent lamps contain mercury and handling them as hazardous waste.