Xanterra_-_Mammoth_Hotel_Limited_Hazardous_Materials_Inspection_Report.pdf

LIMITED HAZARDOUS MATERIALS INSPECTION

REHABILITATION PHASE I

MAMMOTH HOTEL

MAMMOTH HOT SPRINGS

YELLOWSTONE NATIONAL PARK, WYOMING

Prepared for:

Xanterra Parks & Resorts

P.O. Box 587 Yellowstone National Park, WY 82190

Prepared by:

Tetra Tech, Inc.

618 South 25th Street Billings, MT 59501

Tetra Tech Project No. 114-551959

July 15, 2016

Limited Hazardous Materials Inspection Report Rehabilitation Phase I Mammoth Hotel Mammoth Hot Springs, Yellowstone National Park, Wyoming Xanterra Parks & Resorts

TABLE OF CONTENTS

1.0 INTRODUCTION

1.1 Scope of Services

2.0 REGULATORY CRITERIA

2.1 Asbestos-Containing Material

2.2 Lead-Based Paint

2.3 Mercury-Containing Components

2.4 Polychlorinated Biphenyls-Containing Components

2.5 Chlorofluorocarbons-Containing Components

3.0 INSPECTION METHODOLOGY

3.1 Asbestos-Containing Material

3.1.1 Previous Inspection Results

3.1.2 Asbestos Inspection

3.1.3 Assessment

3.2 Lead-Based Paint

3.3 Mercury-Containing Components

3.4 PCB-Containing Components

3.5 Chlorofluorocarbons-Containing Components

4.0 FINDINGS

4.1 Asbestos-Containing Material Findings

4.1.1 Suspected Asbestos-Containing Materials

4.2 Lead-Based Paint Findings

4.2.1 Suspected Lead-Based Paint Materials

4.3 Mercury-Containing Component Findings

4.4 PCB-Containing Component Findings

4.5 Chlorofluorocarbons-Containing Component Findings

5.0 QUALITY ASSURANCE/QUALITY CONTROL

5.1 Field Quality Assurance/Quality Control

5.2 Laboratory Quality Assurance/Quality Control

6.0 RECOMMENDATIONS

6.1 Asbestos-Containing Building Materials

6.2 Mercury-Containing Components

6.3 PCB-Containing Components

6.4 Chlorofluorocarbons-Containing Components

7.0 LIMITATIONS

8.0 REFERENCES

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LIST OF TABLES

Table 1 Summary of Asbestos Definitions Table 2 Summary of Lead-Based Paint Containing Materials Table 3 Summary of Mercury-Containing Components Table 4 Summary of PCB-Containing Components Table 5 Summary of Chlorofluorocarbons-Containing Components

LIST OF APPENDICES

Appendix A Asbestos Materials and Sampling Protocol Appendix B Tetra Tech Personnel Certifications Appendix C Asbestos Bulk Sample Laboratory Report Appendix D Figures Appendix E XRF Performance Characteristic Sheet Appendix F Summary of XRF Results

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LIST OF ACRONYMS

ACBM Asbestos-containing building material ACM Asbestos-containing material AIHA American Industrial Hygiene Association CFC Chlorofluorocarbons CFR Code of Federal Regulations DOT Department of Transportation EPA United States Environmental Protection Agency HUD United States Department of Housing and Urban Development LBP Lead-based paint NESHAP National Emission Standards for Hazardous Air Pollutants OSHA Occupational Safety and Health Administration PCB Polychlorinated biphenyls PLM Polarized light microscopy PPE Personal Protective Equipment QA/QC Quality Assurance/Quality Control RACM Regulated Asbestos-Containing Materials RCRA Resource Conservation and Recovery Act REI Reservoirs Environmental, Inc.

TCLP Toxicity Characteristic Leaching Procedure WDEQ Wyoming Department of Environmental Quality XRF X-Ray Fluorescence

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1.0 INTRODUCTION

At the direction of the Xanterra Parks & Resorts, a limited hazardous materials inspection was conducted as part of Rehabilitation Phase I at the Mammoth Hotel located in Mammoth Hot Springs, Yellowstone National Park, Wyoming. The purpose of the inspection was to identify the potential presence of asbestos-containing materials (ACM), lead-based paint (LBP), mercury-containing components, polychlorinated biphenyls (PCBs), and chlorofluorocarbons (CFCs), in preparation for future renovations of the south end of the building, including the guest reception area, map room, gift shop, reservation center, and guest rooms 101, 201, 301, and 401. This report identifies the procedures utilized by Tetra Tech to determine the presence and location of these materials.

This document provides a summary of:

• Tetra Tech’s scope of services;

• Applicable regulations pertaining to the inspection;

• Inspection methodology;

• Inspection findings; and,

• Recommendations.

The inspection, conducted by Mr. Daniel Lawrence, was conducted June 20 through June 22, 2016. The asbestos materials and sampling protocol used in the inspection is provided in Appendix A. Tetra Tech personnel certifications, pertinent to the inspection services conducted, are provided in Appendix B. The laboratory analytical reports for bulk ACM samples is provided in Appendix C. Approximate sample collection locations are presented on Field Drawing in Appendix D. The Performance Characteristic Sheet for the LBP testing instrument is presented in Appendix E, results of the LBP inspection are contained in Appendix F.

1.1 Scope of Services

The scope of services for this inspection included:

• Visual examination of accessible areas of the subject structure, for suspect ACM, LBP, and PCB building materials;

• Visual examination of accessible areas of the subject structure for components considered to be mercury-containing;

• Visual examination of accessible areas of the subject structure for components considered to be Chlorofluorocarbons-containing;

• Collection of samples of suspected ACMs for laboratory analysis;

• Field testing of suspected LBP building materials;

• Evaluation of analytical data; and,

• Preparation of this final report which outlines the hazardous substances identified within the subject structure.

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2.0 REGULATORY CRITERIA

2.1 Asbestos-Containing Material

Worker exposure to asbestos during construction operations including ACM removal is regulated under 29 Code of Federal Regulations (CFR) 1926.1101. The 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 National Emission Standard for Hazardous Air Pollutants (NESHAP), 40 CFR Part 61, Subpart M. Table 1 presents a summary of pertinent United States Environmental Protection Agency (EPA) definitions under 40 CFR 763.83, as administered NESHAP.

Table 1 Summary of Asbestos Definitions

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

Asbestos-Containing Building Materials (ACBM)

Surfacing ACM, thermal system insulation ACM, or miscellaneous ACM that is found in or on interior structural members or other parts of a public or commercial building.

Assumed Asbestos- Containing Material

ACM that remains un-sampled, but is considered suspect for asbestos content, and must be treated as ACM until proven negative for asbestos content by laboratory analysis or by documentation (e.g., product Safety Data Sheet).

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.

2.2 Lead-Based Paint

LBP is defined as surface coatings with a lead concentration greater than or equal to 1.0-milligrams per square centimeter (mg/cm2) or 0.5 percent (%) by weight (40 CFR Part 745). Deteriorated LBP can cause elevated lead levels in dust and exposure risks to building occupants.

Worker exposure to lead hazards in construction is regulated under 29 CFR 1926.62. OSHA has established provisions for worker protection including, but not limited to: training and medical monitoring requirements for personnel engaging in the oversight and removal of LBP, exposure limits, respiratory protection, PPE, work practices and engineering controls, and storage of wastes.

The handling storage, transport, and disposal of lead or lead-contaminated waste must be conducted in accordance with 40 CFR 260, 40 CFR 261, 40 CFR 262, 40 CFR 263, 40 CFR 264, and 40 CFR 265. Building owners must comply with land disposal restriction notification requirements as required by 40 CFR 268.

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2.3 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. 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 RCRA and the Universal Waste Rule. The Wyoming Department of Environmental Quality (WDEQ) has provided regulatory guidance for the disposal of fluorescent bulbs and ballasts.

2.4 Polychlorinated Biphenyls-Containing Components

PCBs in ballasts and electrical components 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, and must comply with applicable Department of Transportation (DOT) requirements.

2.5 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.

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3.0 INSPECTION METHODOLOGY

The limited hazardous materials inspection attempted to identify concealed building materials such as: heating systems, roofing systems, double layer drywall, flooring under existing flooring, or mechanical systems 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 as Tetra Tech did not dismantle or disassemble some equipment due to other potential site safety hazards.

The assessments focused on the following designated substances.

3.1 Asbestos-Containing Material

3.1.1 Previous Inspection Results

There were no records of previous inspection provided by Xanterra Parks & Resorts personnel to Tetra Tech. Therefore, previous inspection findings were not evaluated as a facet of this inspection.

3.1.2 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, pipe insulation) was not similar in appearance and texture to other materials in the structure, 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:

• MH-F1.1A

Where “MH” would reference the structure ID number; “F1” would reference the material type, in this case, a flooring material; “1” would reference that this was the first type of flooring identified, and “A” would reference the first of three (to seven) samples associated with the homogeneous material.

Upon completion of sampling activities, the bulk samples were delivered, along with completed chain-of-custody documentation, to Reservoirs Environmental, Inc., (REI) laboratory located in Denver, Colorado. REI 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, for identification of mineral forms of asbestos.

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3.2 Lead-Based Paint

The LBP inspection included documenting types of painted building components and substrate materials. Typical building components tested included walls, door units, window units, ceilings and structural members. Substrate materials typically consisted of metal and concrete. The building components tested were cataloged based on location, specific component type, and substrate material.

The EPA and the United States Department of Housing and Urban Development (HUD) define a lead 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).

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 (HUD, 1995, revised 1997 and 2000). For these inspections, Tetra Tech personnel utilized the Niton XLP, Spectrum Analyzer XRF, which automatically calculates measurable amounts of lead in paint by correcting for substrate conditions. The XRF Performance Characteristic Sheet (Appendix E) for the XRF used by Tetra Tech specifies the ranges where XRF results are positive, negative, or inconclusive.

3.3 Mercury-Containing Components

The assessment included the visual inspection of mercury-containing equipment including compact fluorescent lamps, fluorescent U-tubes, fluormeric 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 had labels not identified as “Mercury-Free,” were assumed to be mercury-containing and were documented accordingly.

3.4 PCB-Containing Components

The assessment included the visual inspection 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, and transformers. 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 had labels not identified as “PCB-Free,” were assumed to be PCB-containing and were documented accordingly.

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3.5 Chlorofluorocarbons-Containing Components

The assessment included the visual inspection of miscellaneous components identified during the course of the inspection historically identified as chlorofluorocarbons-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 chlorofluorocarbons-containing components provided by the EPA. Any components that were suspected of containing-chlorofluorocarbons and were either not labeled or had labels not identified as “Chlorofluorocarbons-Free,” were assumed to be chlorofluorocarbons-containing and were documented accordingly.

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4.0 FINDINGS

The limited hazardous materials inspection of the 19,500-square-foot work area was conducted on June 20 through June 22, 2016. The work area consisted of a wood framed structure with interior finishing including wood, ceramic tile, vinyl sheet, and carpeted floors, plaster, and drywall, resting on concrete foundation with crawlspace and walkway tunnels, and covered by a cedar shake or vinyl membrane roof system. The findings and results of the inspection are described in the following section.

4.1 Asbestos-Containing Material Findings

Asbestos inspection services were conducted by an AHERA Accredited Asbestos inspector Mr.

Daniel Lawrence on June 20 through June 22, 2016. The site assessment entailed a visual and physical examination of the structure.

Tetra Tech collected and submitted 85 bulk samples to the laboratory for asbestos analysis.

Based on the analyses, no materials were identified as ACM. A copy of the laboratory analytical reports is provided in Appendix C. Approximate sample collection locations are presented on Figures 1 through 5.

4.1.1 Suspected Asbestos-Containing Materials

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

• Plaster walls and ceilings in Rooms 100, 101, 103, 150, 200, 201, 203, 300, 301, 303, 400, 401, 403, and ST1 (MH-S1.1A, B, C, D, E, F, G)

• Light blue vinyl sheet flooring and associate mastic in restrooms of Guest Rooms 101, 103, 203, and 401 (MH-F1.1A, B, C)

• Yellow carpet mastic in Rooms 100, 101, 103, 150, 200, 201, 203, 300, 301, 303, 400, 401, 403, and ST1 (MH-F6.1A, B, C)

• Orange-peel textured wallboard system on walls and ceilings in Rooms 135-145, L01, and

ST2 (MH-S3.1A, B, C, D, E, F, G)

• Popcorn textured wallboard system on walls and ceiling in Room 146 (MH-S4.1A, B, C, D, E)

• Ceramic tile and grout on floors and walls of Rooms 139, 140, and 143-145 (MH-M16.1A, B, C)

• Brown swirl pattern vinyl sheet flooring and associated mastic in Room R02 (MH-F1.2A, B, C)

• Light orange-peel textured wallboard system on walls and ceilings in Rooms R01-R13 (MH- M3.2A, B, C, D, E, F, G)

• Stucco siding on building exterior (MH-S2.1A, B, C, D, E, F, G)

• Window glazing on building exterior (MH-M29.1A, B, C)

• White 12-inch by 12-inch vinyl floor tile and associated mastic in Room R14 (MH-F2.1A, B, C)

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• Mastic associated with pink fiberglass batt insulation in Attic (MH-M15.1A, B, C)

• Orange-peel texture on fiberboard in Room 151 (MH-S3.3A, B, C)

• Non-textured wallboard system on walls and ceilings in Rooms 147, 150A, 152, R14, and

L01 (MH-M3.1A, B, C)

• Brown vinyl sheet flooring in Room 151 (MH-F1.1A, B, C)

• Foundation concrete throughout basement and crawlspaces (MH-M18.1A, B, C)

• Heavy trowel ceiling texture in Room 147 (MH-S4.2A, B, C, D, E)

• Heavy knockdown ceiling texture in Room L01 (MH-S4.3A, B, C, D, E)

• Tar paper under shake shingles on Roof (MH-M1.1A, B, C)

• Light gray/black vinyl roofing material on Roof (MH-M1.2A, B, C)

• Black tar sealant on vinyl roof material on Roof (MH-M1.3A, B, C)

4.2 Lead-Based Paint Findings

The lead inspection was conducted by Mr. Daniel Lawrence on June 21 through June 22, 2016, and reviewed by EPA Accredited Lead Inspector/Risk Assessor Mr. Roger W. Herman, Jr. XRF testing indicated that lead-containing paint, as defined by OSHA (any detectable amount) is present on interior and exterior components located throughout the structure. LBP, as defined by the EPA (greater than 1 milligram per square centimeter), was identified on building components, and is summarized in Table 2 below. A complete listing of XRF readings collected during this inspection is provided in Attachment E.

Table 2 Summary Mercury-Containing Components

Mammoth Hotel Rehabilitation Phase I Mammoth Hot Springs, Yellowstone National Park, Wyoming

XRF Reading Number(s) Location Material Description Condition

Highest Lead Concentration

(mg/cm2)

5-6, 9, 31-32 Exterior Walls Yellow paint on walls Intact 16.4

10-11, 37 Exterior Walls White paint on exterior windows Intact 15.9

12-13 Exterior Wall White paint on window guard rail Intact 20.3

14-15 Support Columns Yellow paint on column Intact 16.4

16-17 Soffit Yellow paint on soffit Intact 17.1

19-20 Exterior Walls Yellow paint on fire suppression pipe Intact 19.0

25-26, 55-56 Exterior Door Frame Yellow paint on door frame Intact 15.7

38, 50-51, Window Screen White paint on window screen frame Intact 10.9

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Table 2 Summary Mercury-Containing Components

Mammoth Hotel Rehabilitation Phase I Mammoth Hot Springs, Yellowstone National Park, Wyoming

XRF Reading Number(s) Location Material Description Condition

Highest Lead Concentration

(mg/cm2)

45-46, 63-64 Exterior Trim Yellow paint on trim Intact 16.1

79-81, 87-89, 107-108, 117- 118, 135-137, 145-146, 174- 176, 182, 189, 198-199, 205- 207, 216, 218, 242, 244, 281, 291-292, 309- 310, 320, 326- 328, 338-340, 348-350, 359- 360, 372-375, 387-388, 398- 399, 411-413, 421-423, 452-

Interior Windows throughout

White paint on windows and associated components Intact 26.4

94-95, 295, 307, 330, 362, 379, 391, 404, 415, 426, Interior Door Frame in Rooms 137, 146, R02, R04, R08, R09, R10, R11, and R12

White paint on interior door frame Intact 16.4

191, 208, 306, 317, 329, 376- 377, 390, 401, 414, 425

Interior Door Trim in Rooms 400, 301, R02, R03, R04, R08, R09, R10, R11, and R12

White paint on interior door trim Intact 20.5

210, 294, 332, 363, 380, 392, 405, 416, 427

Interior Doors in Rooms 301, 146, R04, R07, R08, R09, R10, R11, and R12

White paint on interior door Intact 14.9

160-161, 450-

Interior Wall Trim in Rooms 145 and L01 White paint on trim Intact 22.3

223 Interior Wall Trim in Room 300 Green paint on trim Intact 17.1

195-196 Stair Railing White paint on stair railing Intact 10.1

234-235 Stair Railing Tan paint on stair railing Intact 10.6

246-247, 253 Walls in ST1 Tan paint on walls Intact 1.4

448-449 Ceiling Support Column in Room L01 White paint on support column Intact 20.7

Mg/cm2 milligrams per square centimeter

4.2.1 Suspected Lead-Based Paint Materials

The following painted components tested from the structure were suspected to contain lead but were confirmed by XRF analyses not to contain lead as defined by EPA:

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• Yellow paint on fire suppression pipe (XRF Reading Number 18)

• White paint on exterior doors (XRF Reading Numbers 21-24, 41-42, 57-58, 69-70)

• Gray paint on exterior stucco siding (XRF Reading Numbers 27-30, 43-44, 61-62, )

• White paint on replacement exterior window components (XRF Reading Numbers 35-36, 49, 52, 54, 65-66)

• Yellow paint on replacement exterior door components (XRF Reading Numbers 39-40, 67-68)

• Gray paint on awning support columns (XRF Reading Numbers 47-48)

• Black paint on metal stair railing (XRF Reading Numbers 59-60)

• Yellow paint on metal stairs (XRF Reading Numbers 71-72)

• Yellow paint on metal stair railing (XRF Reading Numbers 73-74)

• Tan paint on plaster walls in Room 135 (XRF Reading Numbers 75-77)

• Tan paint on drywall walls and ceiling throughout building (XRF Reading Numbers 78, 97- 100, 109-112, 122-124, 127-132, 139-142, 147-152, 178-181, 301-305, 445-447)

• White paint on drywall walls and ceiling throughout building (XRF Reading Numbers 82- 86, 90-92, 96, 103-104, 119-121, 125-126, 260-265, 277-278, 283-289, 311-315, 321- 325, 333-337, 343-347, 353-356, 364-366, 368-369, 382-385, 393-396, 407-410, 417- 420, 428-434, 439-443)

• White paint on replacement interior door frame components in Rooms 137, 139, 146, R02, R03, R05, R06, R07, R08, and R10 (XRF Reading Numbers 93, 101-102, 293, 296, 300, 316, 341, 351, 361, 378, 402-403)

• Tan paint on heat radiators (XRF Reading Numbers 105-106, 115-116, 184)

• White paint on heat radiator (XRF Reading Numbers 389, 400, 454-455)

• Tan paint on wood trim (XRF Reading Numbers 113-114, 133-134, 143-144)

• Stain on wood wall panels (XRF Reading Numbers 153-156)

• White paint on plaster walls and ceiling (XRF Reading Numbers 157-158, 248-250, 254- 255, 259)

• White paint on cabinets (XRF Reading Number 162)

• Stain on interior wood door (XRF Reading Numbers 163-164)

• Tan paint on plaster walls and ceilings (XRF Reading Numbers 171-173, 185-188, 200, 202-204, 211, 213-215, 219-222, 229, 231-233, 237-241, 251-252, 256)

• Tan paint on interior doors and door frames (XRF Reading Numbers 177, 192, 209, 224- 227, 245, 257-258)

• Tan paint on interior window components (XRF Reading Numbers 183, 190, 197, 217, 243)

• Tan paint on fire suppression pipe (XRF Reading Numbers 194)

• Tan paint on cabinets (XRF Reading Numbers 193, 230)

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• Green paint on drywall walls (XRF Reading Numbers 276, 279)

• Green paint on interior window components (XRF Reading Numbers 280, 282)

• White paint on interior trim (XRF Reading Numbers 290, 298, 308, 435-438)

• White paint on replacement interior doors and door frames (XRF Reading Numbers 297, 299, 318, 342, 352, 381, 406)

• White paint on replacement interior window components (XRF Reading Numbers 319, 357-358, 370-371, 386, 397)

4.3 Mercury-Containing Component Findings

During the site assessment the subject structure was visually inspected for potential mercury-containing equipment on June 22, 2016. Mercury-containing components were identified within the structure. The approximate location of the mercury-containing equipment are presented on Figures 6 through 7. A summary of the mercury-containing components, component locations, descriptions, and quantity is summarized in Table 3 below.

Table 3 Summary Mercury-Containing Components

Mammoth Hotel Rehabilitation Phase I Mammoth Hot Springs, Yellowstone National Park, Wyoming

Component ID Number Location Component Description Manufacturer Estimated Quantity

MH-Hg1 Room 147 Circular Fluorescent light bulbs1” Dimeter General Electric 12 Each

MH-Hg2 Rooms R01-R14 Fluorescent light bulbs 4’ Foot Long 1” Dimeter Underwater Labs 296 Each

MH-Hg3 Attic Compact Fluorescent light bulbs General Electric 2 Each

4.4 PCB-Containing Component Findings

PCB inspection services were conducted by Tetra Tech Mr. Daniel Lawrence on June 22, 2016.

The site assessment entailed a visual and physical examination within structure. The approximate location of the PCB-containing components are presented on Figures 8 through 9. A summary of the PCB-containing components, component locations, descriptions, and quantity is summarized in Table 4 below.

Table 4 Summary PCB-Containing Components Mammoth Hotel Rehabilitation Phase I

Mammoth Hot Springs, Yellowstone National Park, Wyoming Component ID Number Location Component Description Manufacturer Estimated Quantity

MH-PCB1 Rooms 147, R01-R14, and Attic Fluorescent light ballast General Electric 86 Each

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4.5 Chlorofluorocarbons-Containing Component Findings

Chlorofluorocarbons inspection services were conducted by Tetra Tech Mr. Daniel Lawrence on June 22, 2016. The site assessment entailed a visual and physical examination within structure.

The approximate location of the Chlorofluorocarbons-containing components are presented on Figures 10. A summary of the Chlorofluorocarbons-containing components, component locations, descriptions, and quantity is summarized in Table 5 inspection.

Table 5 Summary Chlorofluorocarbons-Containing Components

Mammoth Hotel Rehabilitation Phase I Mammoth Hot Springs, Yellowstone National Park, Wyoming

Component ID Number Location Component Description Manufacturer Estimated Quantity

MH-CFC1 Attic Air conditioner Unit Mitsubishi Electric 1 Each

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5.0 QUALITY ASSURANCE/QUALITY CONTROL

5.1 Field Quality Assurance/Quality Control

Field Quality Assurance/Quality Control (QA/QC) procedures undertaken by Tetra Tech field staff included the cleaning of sampling equipment, sample collection, and handling and management procedures, as summarized below:

• New, clean, disposable nitrile gloves were worn when handling samples or sampling equipment. New gloves were worn for every Homogeneous Area sampled.

• Sampling equipment was cleaned before and between samples by wiping the equipment with an alcohol-based wipe.

• Samples submitted for laboratory analyses were identified on the outside of the laboratory-supplied sample bags.

• XRF analyzer was field calibrated prior to testing for each structure.

5.2 Laboratory Quality Assurance/Quality Control

Each laboratory report provided by REI includes a Quality Assurance Report. The REI Quality Assurance Reports are included with each analytical report. Laboratory reports can be found in Appendix D.

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6.0 RECOMMENDATIONS

Tetra Tech’s recommendations concerning the various types of hazardous materials associated with Mammoth Hotel Rehabilitation Phase I Work Area are presented below.

6.1 Asbestos-Containing Building Materials

Tetra Tech has not identified any asbestos-containing materials within the work area. Accordingly Tetra Tech has no additional recommendations at this time.

6.2 Mercury-Containing Components

Tetra Tech recommends that the mercury-containing components identified in Table 3 of this report be removed from the facility prior to the commencement of renovation activities. Mercury-containing components should be managed in a way that prevents leakage, spillage, or damage in a closed container that is structurally sound and compatible with mercury and the contents of the device. Containers should be clearly labeled as “Universal Waste – Mercury Containing Equipment,” and specify the type and amount of individual component.

Wastes are to be transported to an approved disposal facility in accordance with Universal Waste Transporter Regulations specified in 40 CFR Part 273, Subpart D, and must comply with applicable DOT requirements.

6.3 PCB-Containing Components

Tetra Tech recommends that the PCB-containing components identified in Table 4 of this report be removed from the facility prior to the commencement of demolition activities. PCB-containing components should be managed in a way that prevents leakage, spillage, or damage in a closed container that is structurally sound and compatible with PCBs and the contents of the device.

Storage of the materials must comply with 40 CFR 761.65, and containers are required to be labeled, transported, and manifested for disposal in accordance with 40 CFR 761.62, and must comply with applicable DOT requirements.

6.4 Chlorofluorocarbons-Containing Components

Tetra Tech recommends that the CFC-containing components identified in Table 5 of this report be removed from the facility prior to the commencement of demolition activities. CFC-containing components should be managed in a way that prevents leakage, spillage, or damage in a closed container that is structurally sound and compatible with CFCs and the contents of the device.

Storage of the materials must comply with 40 CFR 82, and containers are required to be labeled, transported, and manifested for disposal in accordance with 40 CFR 82, and must comply with applicable DOT requirements.

Tetra Tech, Inc. July 15, 2016 14

Mammoth Hotel Mammoth Hot Springs, Yellowstone National Park, Wyoming Xanterra Parks & Resorts

7.0 LIMITATIONS

The scope of this report is limited to the materials expressly covered and is intended solely for the client to whom it is addressed. The assessment was conducted using standard engineering and scientific judgment, principles and practices, within a practical scope and budget. Generally, the findings, conclusions, and recommendations are based on a limited amount of data (e.g., the number of sample points, and the number of samples submitted for laboratory analyses) interpolated between sampling points, and the actual conditions (e.g., the type, level, and extent of impacted media) on the property may vary from that described above. Any findings regarding site conditions different from those described above upon which this report is based may consequently change Tetra Tech’s conclusions and recommendations.

This report has been prepared to provide information concerning the various types of hazardous materials which may be present in the structure at this site. It includes only those materials that were visible and accessible at the time of our inspection, found in the structure inspected as specified in this report. Our opinions are intended exclusively for use by the Xanterra Parks & Resorts. The scope of services performed by Tetra Tech may not be appropriate to satisfy the needs of other users, and any use or re-use of this document, or the findings presented herein is at the sole risk of the user.

The opinions presented herein apply to the site conditions existing at the time of our investigation.

Therefore, our opinions and recommendations may not apply to future conditions that may exist at the site which we have not had the opportunity to evaluate.

Tetra Tech, Inc. July 15, 2016 15

Mammoth Hotel Mammoth Hot Springs, Yellowstone National Park, Wyoming Xanterra Parks & Resorts

8.0 REFERENCES

Asbestos References

Code of Federal Regulations (CFR), Title 29, Part 1910.1001, Asbestos; General Industry Standard; Final Rule, August 24, 2006.

Code of Federal Regulations (CFR), Title 29, Part 1926.1101, Asbestos; Construction Industry Standard; Final Rule, August 24, 2006.

Code of Federal Regulations (CFR), Title 40, Part 763, Asbestos; Asbestos-Containing Materials in Schools; Final Rule, November 12, 1987.

Code of Federal Regulations (CFR), Title 40, Part 61, Subpart M – National Emission Standard for Asbestos; Final Rule, November 20, 1990, revised June 19, 1995.

Lead References

Code of Federal Regulations (CFR), Title 40, Part 745, Lead; Requirements for Lead-Based Paint Activities in Target Housing and Child Occupied Facilities; Final Rule, August 29, 1996, revised January 5, 2001.

Code of Federal Regulations (CFR), Title 24 Part 35 and Title 40, Part 745, Lead; Requirements for Disclosure of Know Lead-Based Paint and/or Lead-Based Paint Hazards in Housing; Final Rule, March 6, 1996.

Housing and Community Development Act, Residential Lead-Based Paint Hazard Reduction Act, Title X, 1992.

Housing and Urban Development (HUD), Guidelines for the Control of Lead-Based Paint Hazards in Housing, June 1995, revised 1997 and 2000.

Mercury Reference

Code of Federal Regulations (CFR), Title 40, Part 273, Subpart D, Standards for Universal Waste Management, Volume 28, July 1, 2012.

PCB References

Code of Federal Regulations (CFR), Title 40, Subpart D, Section 761.62, Disposal of PCB Bulk Product Waste. July 1, 2014.

Code of Federal Regulations (CFR), Title 40, Subpart D, Section 761.65, Storage for Disposal.

July 1, 2011.

Agency for Toxic Substances and Disease Registry (ATSDR). “ToxFAQs: Polychlorinated Biphenyls.” Internet: http://atsdr1.atsdr.cdc.gov:8080/tfacts17.html, Atlanta, Georgia, USA, 1997.

Chlorofluorocarbons Reference

Code of Federal Regulations (CFR), Title 40, Part 82, Protection of Stratospheric Ozone, Volume 57, No. 147, July 30, 1992.

Tetra Tech, Inc. July 15, 2016 16 http://atsdr1.atsdr.cdc.gov:8080/tfacts17.html, APPENDIX A

ASBESTOS MATERIALS

SAMPLING PROTOCOL

SAMPLING PROTOCOL

Friable Surfacing Material

The number of samples collected from friable surfacing material was determined based on the following protocol developed under EPA Regulations.

1,000 square feet or less Three bulk samples

1,000 to 5,000 square feet Five bulk samples

Over 5,000 square feet Seven bulk samples

Thermal System Insulation

Thermal system insulation was sampled in a randomly distributed manner, with at least three bulk samples collected from each homogeneous material. At least one bulk sample was collected from each homogeneous material of patched thermal system insulation that was not assumed to be

ACBM.

Bulk samples were also collected from each insulated mechanical system where cement or plaster was used on fittings, such as tees, elbows, or valves. The number of samples was sufficient to determine whether the material was asbestos containing. Minimally, at least three samples were collected from each homogenous area.

Bulk samples were not collected from any homogeneous material where the inspector determined that the thermal system insulation is fiberglass, foam glass, rubber, or other non-asbestos containing building material.

Miscellaneous Material

Bulk samples were also collected from each miscellaneous material. The number of samples was sufficient to determine whether the material was asbestos containing. Minimally, at least three samples were collected from each homogenous area.

Non-friable suspected ACBM

The number of samples collected from non-friable suspect ACBM was sufficient to determine whether the material was asbestos containing. Minimally, at least three samples were collected from each homogenous area.

APPENDIX B

TETRA TECH PERSONNEL

CERTIFICATION

APPENDIX C

ASBESTOS BULK SAMPLE

LABORATORY REPORT

Reservoirs Environmental, Inc.

Reservoirs Environmental QA Manual

Effective January 1, 2015

T:\QAQC\Lab\Reservoirs Environmental QA Manual.doc

Subcontract Number: NA

Laboratory Report: RES 354225-1

Project # / P.O. # 114-551959.100

Project Description: Mamoth Hotel Admin Remodel

RES 354225-1

Sincerely, July 11, 2016

Dear Customer, Reservoirs Environmental, Inc. is an analytical laboratory accredited for the analysis of Industrial Hygiene and

Environmental matrices by the National Voluntary Laboratory Accreditation Program (NVLAP), Lab Code 101896-0 for Transmission Electron Microscopy (TEM) and Polarized Light Microscopy (PLM) analysis and the American

Industrial Hygiene Association (AIHA), Lab ID 101533 - Accreditation Certificate #480 for Phase Contrast

Microscopy (PCM) analysis. This laboratory is currently proficient in both Proficiency Testing and PAT programs respectively.

Reservoirs Environmental, Inc. has analyzed the following samples for asbestos content as per your request. The analysis has been completed in general accordance with the appropriate methodology as stated in the attached analysis table. The results have been submitted to your office.

Tetra Tech, Inc. (Billings, MT)

618 S. 25th Street

Billings MT 59101 is the job number assigned to this study. This report is considered highly confidential and the sole property of the customer. Reservoirs Environmental, Inc. will not discuss any part of this study with personnel other than those of the client. The results described in this report only apply to the samples analyzed.

This report must not be used to claim endorsement of products or analytical results by NVLAP or any agency of the

U.S. Government. This report shall not be reproduced except in full, without written approval from Reservoirs

Environmental, Inc. Samples will be disposed of after sixty days unless longer storage is requested. If you have any questions about this report, please feel free to call 303-964-1986.

Jeanne Spencer

President

P: 303-964-1986

F: 303-477-4275

5801 Logan Street, Suite 100 Denver, CO 80216

1-866-RESI-ENV

www.reilab.com

RES Job Number:

Client:

Client Project Number / P.O.:

Client Project Description:

Date Samples Received:

Turnaround:

Date Samples Analyzed:

RES 354225-1

Tetra Tech, Inc. (Billings, MT) 114-551959.100 Mamoth Hotel Admin Remodel June 29, 2016

3-5 Day July 11, 2016

TABLE: PLM BULK ANALYSIS, PERCENTAGE COMPOSITION BY VOLUME

Reservoirs Environmental, Inc.

Reservoirs Environmental QA Manual

Effective January 1, 2015 Q:\QAQC\LAB\Reservoirs Environmental QA Manual.doc

RESERVOIRS ENVIRONMENTAL INC.

NVLAP Lab Code 101896-0

Client Sample Number

Lab ID Number

L A Y E R

Mineral

Method: EPA 600/R-93/116 - Short Report, Bulk

Physical Description

Sub Part

Visual Estimate

ND=None Detected TR=Trace, <1% Visual Estimate Trem/Act=Tremolite/Actinolite

Non Asbestos Fibrous

Components

Non- Fibrous

Components

Asbestos Content

100TRMH-S1.1A EM 1658939 White granular plaster w/ off white paintA 100 ND 100TRMH-S1.1B EM 1658940 White granular plaster w/ off white paintA 100 ND 100TRMH-S1.1C EM 1658941 White granular plaster w/ off white paintA 100 ND 100TRMH-S1.1D EM 1658942 White granular plaster w/ off white paintA 100 ND 100TRMH-S1.1E EM 1658943 White granular plaster w/ off white paintA 100 ND 100TRMH-S1.1F EM 1658944 White granular plaster w/ off white paintA 100 ND 100TRMH-S1.1G EM 1658945 White granular plaster w/ off white paintA 100 ND

8020MH-F1.1A EM 1658946 Light gray flooring w/ tan fibrous woven backing materialA 100 ND 973MH-F1.1B EM 1658947 Tan masticA 2 ND

100TRTan resinous materialB 3 ND 8020Light gray flooring w/ tan fibrous woven backing materialC 95 ND

100TRMH-F1.1C EM 1658948 Light tan masticA 1 ND 1000Light brown resinous materialB 4 ND

8020Light gray flooring w/ tan fibrous woven backing materialC 95 ND

TEM Analysis recommended for organically bound material (i.e. floor tile) if PLM results are <1%.

P: 303-964-1986 F: 303-477-4275

1-866-RESI-ENV

www.reilab.com

5801 Logan Street, Suite 100, Denver, CO 80216

Client Project Number / P.O.:

Client Project Description:

Date Samples Received:

Turnaround:

Date Samples Analyzed:

RES 354225-1

Tetra Tech, Inc. (Billings, MT) 114-551959.100 Mamoth Hotel Admin Remodel June 29, 2016

3-5 Day July 11, 2016

TABLE: PLM BULK ANALYSIS, PERCENTAGE COMPOSITION BY VOLUME

Reservoirs Environmental, Inc.

Reservoirs Environmental QA Manual

Effective January 1, 2015 Q:\QAQC\LAB\Reservoirs Environmental QA Manual.doc

RESERVOIRS ENVIRONMENTAL INC.

NVLAP Lab Code 101896-0

Client Sample Number

Lab ID Number

L A Y E R

Mineral

Method: EPA 600/R-93/116 - Short Report, Bulk

Physical Description

Sub Part

Visual Estimate

ND=None Detected TR=Trace, <1% Visual Estimate Trem/Act=Tremolite/Actinolite

Non Asbestos Fibrous

Components

Non- Fibrous

Components

Asbestos Content

982MH-F6.1A EM 1658949 Light tan mastic w/ off white/brown paintA 100 ND 955MH-F6.1B EM 1658950 Light tan mastic w/ off white/brown paint & debrisA 100 ND 973MH-F6.1C EM 1658951 Light tan mastic w/ off white/brown paint & debrisA 100 ND

1000MH-S3.1A EM 1658952 White texture w/ off white paintA 5 ND 1090White tapeB 5 ND

1000White joint compoundC 5 ND 8020White/tan drywallD 85 ND

1000MH-S3.1B EM 1658953 White joint compoundA 4 ND 1090White tapeB 5 ND

1000White texture w/ off white paintC 6 ND 7525White/tan drywallD 85 ND

TEM Analysis recommended for organically bound material (i.e. floor tile) if PLM results are <1%.

P: 303-964-1986 F: 303-477-4275

1-866-RESI-ENV

www.reilab.com

Client Project Number / P.O.:

Client Project Description:

Date Samples Received:

Turnaround:

Date Samples Analyzed:

RES 354225-1

Tetra Tech, Inc. (Billings, MT) 114-551959.100 Mamoth Hotel Admin Remodel June 29, 2016

3-5 Day July 11, 2016

TABLE: PLM BULK ANALYSIS, PERCENTAGE COMPOSITION BY VOLUME

Reservoirs Environmental, Inc.

Reservoirs Environmental QA Manual

Effective January 1, 2015 Q:\QAQC\LAB\Reservoirs Environmental QA Manual.doc

RESERVOIRS ENVIRONMENTAL INC.

NVLAP Lab Code 101896-0

Client Sample Number

Lab ID Number

L A Y E R

Mineral

Method: EPA 600/R-93/116 - Short Report, Bulk

Physical Description

Sub Part

Visual Estimate

ND=None Detected TR=Trace, <1% Visual Estimate Trem/Act=Tremolite/Actinolite

Non Asbestos Fibrous

Components

Non- Fibrous

Components

Asbestos Content

1000MH-S3.1C EM 1658954 White joint compoundA 5 ND 1090White tapeB 7 ND

1000Off white paint w/ white textureC 8 ND 7030White/tan drywallD 80 ND

1000MH-S3.1D EM 1658955 White joint compoundA 2 ND 1000Off white paint w/ white textureB 3 ND

1090White tapeC 3 ND 9010White/tan drywallD 92 ND

1000MH-S3.1E EM 1658956 White texture w/ off white paintA 4 ND 1090White tapeB 4 ND

1000White joint compoundC 4 ND 8515White/tan drywallD 88 ND

TEM Analysis recommended for organically bound material (i.e. floor tile) if PLM results are <1%.

P: 303-964-1986 F: 303-477-4275

1-866-RESI-ENV

www.reilab.com

Client Project Number / P.O.:

Client Project Description:

Date Samples Received:

Turnaround:

Date Samples Analyzed:

RES 354225-1

Tetra Tech, Inc. (Billings, MT) 114-551959.100 Mamoth Hotel Admin Remodel June 29, 2016

3-5 Day July 11, 2016

TABLE: PLM BULK ANALYSIS, PERCENTAGE COMPOSITION BY VOLUME

Reservoirs Environmental, Inc.

Reservoirs Environmental QA Manual

Effective January 1, 2015 Q:\QAQC\LAB\Reservoirs Environmental QA Manual.doc

RESERVOIRS ENVIRONMENTAL INC.

NVLAP Lab Code 101896-0

Client Sample Number

Lab ID Number

L A Y E R

Mineral

Method: EPA 600/R-93/116 - Short Report, Bulk

Physical Description

Sub Part

Visual Estimate

ND=None Detected TR=Trace, <1% Visual Estimate Trem/Act=Tremolite/Actinolite

Non Asbestos Fibrous

Components

Non- Fibrous

Components

Asbestos Content

982MH-S3.1F EM 1658957 White joint compoundA 2 ND 1090White tapeB 3 ND

1000Off white paint w/ white textureC 8 ND 8515White/tan drywallD 87 ND 991MH-S3.1G EM 1658958 White joint compoundA 2 ND 1090White tapeB 3 ND

1000White texture w/ off white paintC 20 ND 9010White/tan drywallD 75 ND

1000MH-S4.1A EM 1658959 White texture w/ greenish white paint & white compoundA 10 ND 8515White/tan drywallB 90 ND

1000MH-S4.1B EM 1658960 White texture w/ greenish white paint & white compoundA 8 ND 9010White/tan drywallB 92 ND

TEM Analysis recommended for organically bound material (i.e. floor tile) if PLM results are <1%.

P: 303-964-1986 F: 303-477-4275

1-866-RESI-ENV

www.reilab.com

Client Project Number / P.O.:

Client Project Description:

Date Samples Received:

Turnaround:

Date Samples Analyzed:

RES 354225-1

Tetra Tech, Inc. (Billings, MT) 114-551959.100 Mamoth Hotel Admin Remodel June 29, 2016

3-5 Day July 11, 2016

TABLE: PLM BULK ANALYSIS, PERCENTAGE COMPOSITION BY VOLUME

Reservoirs Environmental, Inc.

Reservoirs Environmental QA Manual

Effective January 1, 2015 Q:\QAQC\LAB\Reservoirs Environmental QA Manual.doc

RESERVOIRS ENVIRONMENTAL INC.

NVLAP Lab Code 101896-0

Client Sample Number

Lab ID Number

L A Y E R

Mineral

Method: EPA 600/R-93/116 - Short Report, Bulk

Physical Description

Sub Part

Visual Estimate

ND=None Detected TR=Trace, <1% Visual Estimate Trem/Act=Tremolite/Actinolite

Non Asbestos Fibrous

Components

Non- Fibrous

Components

Asbestos Content

1000MH-S4.1C EM 1658961 White compound w/ green paintA 5 ND 1000Light green paint w/ white textureB 6 ND

8515Light pink/tan drywallC 89 ND 982MH-S4.1D EM 1658962 Green/white paint w/ white compoundA 5 ND

1000Gray paint w/ white textureB 10 ND 8515Light pink/tan drywallC 85 ND

1000MH-S4.1E EM 1658963 White compound w/ white paintA 10 ND 1000Light green paint w/ white textureB 15 ND

8515Light/tan drywallC 75 ND 1000MH-M16.1A EM 1658964 Off white/light brown resinous materialA 3 ND 100TROff white granular groutB 5 ND 100TRGray granular plasterC 37 ND 1000White ceramic tileD 55 ND

TEM Analysis recommended for organically bound material (i.e. floor tile) if PLM results are <1%.

P: 303-964-1986 F: 303-477-4275

1-866-RESI-ENV

www.reilab.com

Client Project Number / P.O.:

Client Project Description:

Date Samples Received:

Turnaround:

Date Samples Analyzed:

RES 354225-1

Tetra Tech, Inc. (Billings, MT) 114-551959.100 Mamoth Hotel Admin Remodel June 29, 2016

3-5 Day July 11, 2016

TABLE: PLM BULK ANALYSIS, PERCENTAGE COMPOSITION BY VOLUME

Reservoirs Environmental, Inc.

Reservoirs Environmental QA Manual

Effective January 1, 2015 Q:\QAQC\LAB\Reservoirs Environmental QA Manual.doc

RESERVOIRS ENVIRONMENTAL INC.

NVLAP Lab Code 101896-0

Client Sample Number

Lab ID Number

L A Y E R

Mineral

Method: EPA 600/R-93/116 - Short Report, Bulk

Physical Description

Sub Part

Visual Estimate

ND=None Detected TR=Trace, <1% Visual Estimate Trem/Act=Tremolite/Actinolite

Non Asbestos Fibrous

Components

Non- Fibrous

Components

Asbestos Content

1000MH-M16.1B EM 1658965 Dark brown resinous materialA 1 ND 100TRLight tan granular materialB 39 ND 1000White ceramic tileC 60 ND 1000MH-M16.1C EM 1658966 Dark brown resinous materialA 2 ND 100TRLight tan granular materialB 28 ND 1000White ceramic tileC 70 ND

7030MH-F1.2A EM 1658967 Tan/multi-colored sheet vinyl w/ tan fibrous woven backing material

A 100 ND

1000MH-F1.2B EM 1658968 Yellow adhesiveA 3 ND 7030Tan/multi-colored sheet vinyl w/ tan fibrous woven backing material

B 97 ND

1000MH-F1.2C EM 1658969 Yellow adhesiveA 1 ND 7030Tan/multi-colored sheet vinyl w/ tan fibrous woven backing material

B 99 ND

TEM Analysis recommended for organically bound material (i.e. floor tile) if PLM results are <1%.

P: 303-964-1986 F: 303-477-4275

1-866-RESI-ENV

www.reilab.com

Client Project Number / P.O.:

Client Project Description:

Date Samples Received:

Turnaround:

Date Samples Analyzed:

RES 354225-1

Tetra Tech, Inc. (Billings, MT) 114-551959.100 Mamoth Hotel Admin Remodel June 29, 2016

3-5 Day July 11, 2016

TABLE: PLM BULK ANALYSIS, PERCENTAGE COMPOSITION BY VOLUME

Reservoirs Environmental, Inc.

Reservoirs Environmental QA Manual

Effective January 1, 2015 Q:\QAQC\LAB\Reservoirs Environmental QA Manual.doc

RESERVOIRS ENVIRONMENTAL INC.

NVLAP Lab Code 101896-0

Client Sample Number

Lab ID Number

L A Y E R

Mineral

Method: EPA 600/R-93/116 - Short Report, Bulk

Physical Description

Sub Part

Visual Estimate

ND=None Detected TR=Trace, <1% Visual Estimate Trem/Act=Tremolite/Actinolite

Non Asbestos Fibrous

Components

Non- Fibrous

Co…