-REPORT- ASBESTOS AND LEAD INSPECTION ......-REPORT- ASBESTOS AND LEAD INSPECTION, ASSESSMENT, SAMPLING Property: Tom’s Truck Sales 1022-1030 East 4th rdStreet, nd308/310 Breeden

-REPORT-

ASBESTOS AND LEAD

INSPECTION, ASSESSMENT, SAMPLING

Property:

Tom’s Truck Sales

1022-1030 East 4th Street, 308/310 Breeden Street, 927-1001 East 3rd Street, 905 East 2nd Street

Santa Ana, California

Report date: July 25, 2018

Altec Testing & Eng. Inc.

Asbestos-Containing Materials & Lead Paint

Inspection, Assessment, Sampling Report

Page 2

Scope of work: Inspection, Assessment and Sampling for

Asbestos-Containing Materials (ACMs) and Lead Paint

Property location: Tom’s Truck Sales

1022-1030 East 4th Street, 308/310 Breeden Street,

927-1001 East 3rd Street, 905 East 2nd Street


Date(s) of sampling: July 11-12, 2018

Altec Project No. 419-2018273

Requested by:

Bernard Sentianin

Environmental Equalizers, Inc.

2195 Faraday Avenue, Suite K

Carlsbad, California 92008

(760) 431-3747 Telephone

Inspection, assessment and

sampling by:

Altec Testing & Engineering, Inc.

6035 Fremont Street

Riverside, California 92504

(951) 352-6510 Telephone

Mason S. Adams

Certified Asbestos Consultant #15-5479

Lead Sampling Technician #21996

Lynn A. Laborde

Certified Asbestos Consultant #92-0495

Lead Inspector, Risk Assessor, Project Monitor #7203




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TABLE OF CONTENTS

1.0 INTRODUCTION .................................................................................................................................. 4

2.0 RESULTS SUMMARY .......................................................................................................................... 5

3.0 SPECIAL NOTATIONS & QUALIFICATIONS .................................................................................. 6

4.0 ASBESTOS ............................................................................................................................................. 6

5.0 LEAD PAINT ....................................................................................................................................... 12

Appendices

Appendix A - Common Acronyms/Definitions

Appendix B - Supplemental Information (Sampling Overview, Strategy, Protocol, Limitations)

Appendix C - Inspector Certificates

Appendix D - Laboratory Certifications, XRF PCS

Appendix E - Analytical Results, Lead XRF Data Sheets, and Chain of Custody Forms

Appendix F - Sample Location Maps




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1.0 INTRODUCTION

Altec Testing & Engineering, Inc. (Altec) performed a visual inspection and testing/sampling to

identify asbestos-containing materials (ACMs) and lead in paint which could present an

exposure/release risk during renovation/demolition activities at the following property:

Address:

1022-1030 East 4th Street

308/310 Breeden Street

927-1001 East 3rd Street

905 East 2nd Street


Type of structures: Commercial – Tom’s Truck Sales

Survey Date: July 11-12, 2018

Intended work: Demolition

The specific asbestos scope of work included:

• Asbestos - Inspect the scope of work areas and collect bulk samples of suspect asbestos-containing materials and obtain laboratory analysis for asbestos by Polarized Light

Microscopy (PLM).

The specific lead paint scope of work included:

• Lead XRF - Inspect the scope of work areas and perform testing to identify LBP on structural components using an x-ray fluorescence (XRF) analyzer

• Lead Bulk - Collect representative samples of damaged or deteriorating painted components where possible and obtain laboratory results for lead in percent dry weight or

parts per million by EPA Method 7000, 7420 or equivalent.

This work was performed exclusively within the scope of work areas to identify the types and

approximate quantities of ACMs and lead paint that will require special handling, removal and

disposal procedures prior to construction efforts.




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2.0 RESULTS SUMMARY

Asbestos Results Summary

The following asbestos-containing materials were identified1:

➢ Green 9” by 9” VFT and Black Mastic ➢ Green Streak 9” by 9” VFT ➢ Transite Pipe ➢ White Speckled 12” by 12” VFT ➢ Joint Compound ➢ Interior Window Putty ➢ Grey/Black Penetration Tar ➢ Black Roofing (Former Post Office)

Action Needed Asbestos removal by California certified asbestos workers is necessary prior to disturbance of these materials.

Exercise caution during construction and notify a certified asbestos consultant (CAC) for sampling if additional

suspect ACMs are found and will be disturbed.

Lead Paint XRF Testing Result Summary

No lead-containing components were identified by XRF testing2.

Action Needed

No action needed. Cal/OSHA requires that renovation or demolition work performed on components containing

lead concentrations above 600 parts per million (ppm) must be performed with appropriate personal protective

measures until employee exposure assessments establish that air concentrations are below the lead permissible

exposure limit (PEL). Removal or stabilization of LBP components should be performed by CDPH certified lead

workers.

Lead Paint Chip Sample Result Summary

The following paints were identified with lead concentrations above 600 ppm by laboratory analysis:

➢ Grey Exterior Walls & Fascia – 936 East 3rd Street

Please note: Bulk paint sampling was only performed for damaged exterior paint. Intact paint may contain lead

above 600 ppm as well.

Action Needed

See special notations in Section 3.1 and Section 5.2 regarding Cal/OSHA worker protection and waste

characterization obligations for demolition and renovation contractors.

1 ACM = Asbestos concentrations of greater than 1%, ACCM = Asbestos concentrations 0.1% by weight or greater. 2 Lead concentrations exceeding the positive threshold of 1.0 mg/cm2




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3.0 SPECIAL NOTATIONS & QUALIFICATIONS

3.1 Special Notations

The following information should be provided to any renovation/demolition contractors performing

work at the property:

Cal/OSHA requires that renovation or demolition work performed on components containing lead

concentrations above 600 ppm must be performed with appropriate personal protective measures

until employee exposure assessments establish that air concentrations are below the lead PEL.

Waste characterization sampling and analysis will be necessary for any construction waste/debris

containing lead in concentrations above 50 parts per million (ppm) prior to disposal.

3.2 Inspectors Qualifications

Altec’s asbestos inspectors hold State of California Department of Occupational Safety and Health

(DOSH) Certified Asbestos Consultant (CAC) licenses and maintain current AHERA certifications

in Asbestos Building Inspection, Management Planning, Project Design, and Abatement

Supervision. Altec’s lead sampling technicians have completed an EPA and State of California

Department of Public Health (CDPH) approved curriculum in Lead in Construction Inspector/Risk

Assessor and/or Sampling Technician Training. They are certified by the State of California

Department of Public Health (CDPH) as a Lead in Construction Sampling Technician. Altec’s

Sampling Techs work under the direct supervision of a CDPH Lead Inspector/Risk Assessor. Altec

defines direct supervision as follows: (1) following clear and concise instruction for the testing of

paint/coatings, collection of samples, and the assessment of sampled media, (2) establishing

forms/maps used to document the assessment information, (3) being physically present at the

testing/sampling location during testing, or being available at all times during the inspection and

available to respond to the location if needed, (4) daily monitoring of project progress, and (5)

reviewing and approving all collected data. Personnel certifications are provided in Appendix C.

4.0 ASBESTOS

4.1 Laboratory Analysis

The bulk samples collected were analyzed for asbestos by Polarized Light Microscopy (PLM) using

the Environmental Protection Agency (EPA) Methods EPA/600/R-93/116 and EPA/600/M4-82-020

by the following National Institute of Standards and Technology’s (NIST) National Voluntary

Laboratory Accreditation Program (NVLAP) accredited laboratory:

Laboratory QuanTEM Laboratories, 2033 Heritage Park Drive, Oklahoma City, OK

4.2 PLM Results (Visual Estimation)

Polarized Light Microscopy (PLM) is the method most often used for the analysis of

construction/building materials for the presence of asbestos fibers. The method utilizes the unique

features of polarized light to observe mineral specific optical properties in prepared samples. In this

manner, PLM can differentiate asbestos from non-asbestos fibers and further classify the various

types of asbestos. The PLM procedure is an economical technique for screening a large number of




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samples; however, there are limitations due to the magnification (100-400X) employed and due to

other interferences present in the building material matrices. PLM results are reported as a

percentage of the total sample. The method utilizes two protocols for the quantification process,

which include visual estimation and point counting. Depending on the sample matrix, PLM

analytical sensitivity can be a fraction of a percent. Gravimetric reduction protocols further enhance

this technique's ability to accurately quantify and qualify asbestos.

The collected samples were grouped into homogeneous categories, assigned individual sample

numbers, sealed in plastic bags, and transported under proper chain-of-custody documentation to

the selected laboratory.

The following is a summary of the materials that were determined to be asbestos-containing. A list

of the materials that were determined to not contain asbestos fibers are listed in Table 3. Most

asbestos-containing materials must be removed prior to any renovation or demolition. Abatement

contractors shall verify ACM quantities prior to providing bids for removal work.

Table 1 - Positive Asbestos Materials (Asbestos)

Sample

No.

Material

Description Sample Location Friability Condition

Approx.

Quantity

Result

(Asbestos

Type)

16-18 Green 9” by 9”

VFT

1028/1030 E. 4th St. –

Warehouse

Category I

non-friable

Good 1,250 ft2 10%

Chrysotile

16a-18a Black Mastic 1028/1030 E. 4th St. – Beneath

Green VFT

Category I

non-friable

Good 1,250 ft2 5%

Chrysotile

19-21 Green Streak 9” by

9” VFT

1028-1030 E. 4th St. – 1st Floor

Office/Storages/Hallway

Category I

non-friable

Good 1,000 ft2 8%

Chrysotile

Not

Sampled

Transite Pipe 1028/1030 E. 4th St. – 1st Floor

Hallway Hot Water Closet

near Men’s Bathroom

Category II

non-friable

Good 15 LF Assumed

Positive

34-36 White Speckled

12” by 12” VFT

308-310 Breeden St./1001 E.

3rd St. – 2nd Floor Offices

Category I

non-friable

Good 1,050 ft2 3-4%

Chrysotile

44,46,48 White/Tan Joint

Compound

308/310 Breeden St./1001 E.

3rd St. – Warehouse (North

West Area)

Category II

non-friable

Fair 3,000 ft2 3%

Chrysotile

49-51 Tan Window Putty 927-929 E. 3rd St. – Oil

Storage Areas

Category II

non-friable

Fair 150 ft2 4%

Chrysotile

106-108 Grey/Black

Penetration Tar

936 E. 3rd St. – South East

Offices Roof

Category I

non-friable

Good 10 ft2 20%

Chrysotile

124-126 Black Roofing 927-929 E. 3rd St. – Former

Post Office Roof

Category I

non-friable

Damaged 750 ft2 10%

Chrysotile

130-132 Grey/Black

Penetration Tar

308-310 Breeden St./1001 E.

3rd St. – Roof

Category I

non-friable

Good 200 ft2 25%

Chrysotile

4.3 PLM by 1000-Point Count Analysis with Gravimetric Reduction

In PLM point counting analysis, a graticule containing a crosshair is placed in the ocular (eye piece)

of the microscope. The place at which the crosshairs meet is known as the “point”. The analyst




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moves the slide around under the microscope until the “point” lands on a particle. If it is visually

identified as an asbestos fiber the point is counted as an asbestos point. If it is visually identified as

a non-asbestos particle, the point is counted as a non-asbestos point. If the point falls on an empty

area of the slide nothing is counted and the slide is moved to a new field of view. The process is

repeated until 400 to 1000 asbestos and non-asbestos points are counted. The total number of

asbestos points is found and is divided by the total number of points counted (both asbestos and

non-asbestos). The result is multiplied by 100 to obtain the percent of asbestos in the sample.

Gravimetry is a technique that enhances PLM in the quantitation of asbestos in bulk building

materials by eliminating or significantly reducing the organic matter in the sample (the asbestos

fibers remain). It improves the ability to detect asbestos fibers in the sample and also improves the

quantification. Prior to slide preparation, the sample is dried, weighed and placed in a high

temperature (up to 500 C°) furnace for a 6-hour period. It is then cooled and weighed. Further treatment with dilute hydrochloric acid may be used to remove carbonates and other acid soluble

substances in the sample. The remaining material is then washed with water, dried and weighed.

The residue is now examined by PLM or other techniques for the presence of asbestos fibers.

Using PLM point counting is performed to determine the concentration of asbestos fibers in the

residue. Once the point count result is obtained, the weight of the residue is used to calculate the

concentration of asbestos in the original sample.

The following table lists the samples that were additionally analyzed by the 1000-point count

method.

Table 2 – 1000-Point Count Results (Asbestos)

Altec

Sample

ID Material Description Sample Location

Asbestos

Type

Standard

PLM

Result (%)

1000 Point

Count Result

(%)

44 White Joint Compound 308-310 Breeden St./1001 E. 3rd

St. – Warehouse (North West

Area)

Chrysotile 3% 0.4%

46 White Joint Compound 308-310 Breeden St./1001 E. 3rd


Area)

Chrysotile 3% 0.8%

48 Tan Joint Compound 308-310 Breeden St./1001 E. 3rd


Area)

Chrysotile 3% 0.6%

Joint Compound

Additional analysis using the 1,000-point count method demonstrated that the above materials

contains trace amounts (between 0.1% and 1%) of chrysotile asbestos. Materials containing trace

asbestos are not regulated by the SCAQMD and can be disposed of as construction debris; however,

they are regulated by Cal/OSHA. An initial exposure assessment should be conducted in

accordance with Title 8 CCR section 1529 during any disturbance of this material. The estimated

amount present is 3,000 square feet.




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4.4 Types of Asbestos-Containing Materials

All ACMs must be removed prior to any renovation or demolition activities that could result in

damage or disturbance. Regardless of the quantity estimates provided above or in the narratives

below, the abatement contractor must verify the quantities of all ACMs prior to bid submission.

Regulated Asbestos-Containing Material (RACM) is (1) a friable asbestos-containing material,

(2) a Category I non-friable ACM that has become friable, (3) a Category I non-friable ACM that

will be or has been subjected to sanding, grinding, cutting or abrading or (4) a Category II non-

friable ACM that has a high probability of becoming or has become crumbled, pulverized, or

reduced to powder by the forces expected to act on the material in the course of demolition or

renovation operations. An initial exposure assessment should be conducted in accordance with Title

8 CCR section 1529 during any disturbance of these materials.

Friable refers to any material containing more than 1% asbestos as determined by Polarized Light

Microscopy (PLM), that, when dry, can be crumbled, pulverized or reduced to powder by hand

pressure.

Category I ACM (Non-Friable) refers to asbestos containing packing, gaskets, resilient floor

covering, Galbestos™ siding and roofing, and asphalt roofing products containing more than 1%

asbestos. Asphalt roofing products, which may contain asbestos, include built-up roofing; asphalt-

containing single ply membrane systems; asphalt shingles; asphalt-containing underlayment felts;

asphalt-containing roof coatings and mastics; and asphalt-containing base flashings. ACM roofing

products that use other bituminous or resinous binders (such as coal tars or pitches) are also

considered to be Category I ACM.

Category II ACM (Non-Friable) refers to any material that contains greater than 1% asbestos and

is not friable and is not a Category I ACM. Category II includes asbestos-cement shingles, tiles, and

transite boards or panels containing more than 1% asbestos. In general, Category II ACM is more

likely to become friable when damaged than is Category I ACM.

4.4.1 Friable (RACM)

No regulated asbestos-containing materials were identified.

4.4.2 Category I Non-Friable ACM

Green 9” by 9” VFT and Black Mastic

Asbestos-containing green 9” by 9” VFT and associated black mastic is located in the warehouse

area of 1028/1030 E. 4th Street. These materials contain 10% and 5% chrysotile asbestos and are

presently in good condition. The estimated amount present is 1,250 square feet.

Green Streak 9” by 9” VFT

Asbestos-containing green streak 9” by 9” VFT is located throughout the 1st floor hallway, office,

and storages of 1028/1030 E. 4th Street. This material contains 8% chrysotile asbestos and is

presently in good condition. The estimated amount present is 1,000 square feet.




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White Speckled 12” by 12” VFT

Asbestos-containing white speckled 12” by 12” VFT is located in the 2nd floor office area of 308-

310 Breeden Street/1001 E. 3rd Street. This material contains between 3% and 4% chrysotile

asbestos and is presently in good condition. The estimated amount present is 1,050 square feet.

Grey/Black Penetration Tar

Asbestos-containing gray/black penetration tar is located on the roof of the South East offices of

936 E. 3rd Street, and the roof of 308-310 Breeden St./1001 E. 3rd Street. These materials contain

20% and 25% chrysotile asbestos and are presently in good condition. The total estimated amount

present is 210 square feet.

Black Roofing

Asbestos-containing black roofing is located on the roof of the former post office building at 927-

929 E. 3rd Street. This material contains 10% chrysotile asbestos and is presently in damaged

condition. The estimated amount present is 750 square feet.

4.4.3 Category II Non-Friable ACM

Transite Pipe

Asbestos-containing transite piping is located in the hallway hot water heater closet near the men’s

restroom of 1028/1030 E. 4th Street. This material was assumed positive and is presently in good

condition. The estimated amount present is 15 linear feet.

White/Tan Joint Compound

Asbestos-containing joint compound is located in the North West area of the warehouse in 308-310

Breeden Street/1001 E. 3rd Street. This material contains 3% chrysotile asbestos and is presently in

fair condition. Additional analysis using the 1,000-point count method demonstrated that the above

materials contains trace amounts (between 0.1% and 1%) of chrysotile asbestos. Materials

containing trace asbestos are not regulated by the SCAQMD and can be disposed of as construction

debris; however, they are regulated by Cal/OSHA. An initial exposure assessment should be

conducted in accordance with Title 8 CCR section 1529 during any disturbance of this material.

Because joint compound cannot be separated from drywall (or skim coat), these materials are

considered integral systems, and both must be treated as trace asbestos-containing for

removal/disposal purposes. The estimated amount present is 3,000 square feet.

Tan Window Putty

Asbestos-containing tan window putty is located on the windows in the oil storage areas of 927-929

E. 3rd Street. This material contains 4% chrysotile asbestos and is presently in fair condition. The

estimated amount present is 150 square feet.

4.5 Non-ACMs

The following is a list of the sampled materials that did not contain asbestos in concentrations

above the analytical detection limits.




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Table 3 – Non-ACM Results

4.6 Previous ACM Survey Reports

No previous asbestos survey reports or data were provided.

Sample

Nos. Material Description Sample Location

1-3 Brown 9” by 9” VFT & Black Mastic 1028/1030 E. 4th St. – 2nd Floor Apartment

Bathroom

4-9 Drywall/Joint Compound 1028/1030 E. 4th St. – Throughout Building

10-12 Flower Wall Paper w/ Woven Backing 1028/1030 E. 4th St. – 2nd Floor Storage

13-15 Ceiling/Wall Plaster 1028/1030 E. 4th St. – Throughout 1st Floor

19a-21a Black Mastic 1028/1030 E. 4th St. – Beneath Green Streak 9” by

9” VFT

22-27 1’ by 1’ Pinhole Ceiling Tile and Brown

Adhesive

1028/1030 E. 4th St. – Warehouse

28-30 1’ by 1’ Smooth Ceiling Tile 1028/1030 E. 4th St. – 1st Floor Storages

31-33 White RSF 1028/1030 E. 4th St. – 1st Floor Restrooms

34a-36a Black/Brown Mastic 308-310 Breeden St./1001 E. 3rd Street – 2nd Floor

Offices

34b-36b Black Tar Paper 308-310 Breeden St./1001 E. 3rd Street – 2nd Floor

Offices

37-39 Interior Window Putty 308-310 Breeden St./1001 E. 3rd Street – 2nd Floor

Offices

40-42 Brown Composite Ceiling Tile 308-310 Breeden St./1001 E. 3rd Street – 2nd Floor

Offices (On Ground)

43,45,47 Drywall (Treated as trace ACM due to

positive joint compound)

308-310 Breeden St./1001 E. 3rd Street – North

West Area of Warehouse

52-60 Wall Texture/Drywall/Joint Compound 927-929 E. 3rd St. – Oil Storage Restroom

61-63 Grey 12” by 12” VFT and Yellow Mastic 927-929 E. 3rd St. – Former Post Office

64-69 Drywall/Joint Compound 927-929 E. 3rd St. – Former Post Office

70-72 Ceiling Tile 927-929 E. 3rd St. – Former Post Office

73-75 Brown Peel-n-Stick Wall Tile 927-929 E. 3rd St. – Former Post Office

76-78 Grey 12” by 12” VFT and Brown Mastic 936 E. 3rd St. – Stairs/Break Area

79-81 1’ by 1’ Pinhole Ceiling Tile 936 E. 3rd St. – Break Area

82-84 2’ by 4’ Ceiling Tile 936 E. 3rd St. – Break Area

85-87 White Cove Base Adhesive 936 E. 3rd St. – Break Area

88-91,

101,102

Drywall/Joint Compound 936 E. 3rd St. – Break Area/South East Offices

(Dispatch)

92-97 Multiple Layers Flooring 936 E. 3rd St. – South East Offices (Dispatch)

98-100 Ceiling/Wall Texture 936 E. 3rd St. – South East Offices (Dispatch)

103-105 Grey Cap Sheet 936 E. 3rd St. – South East Offices Roof (Flat Roof)

109-111 Window Putty 936 E. 3rd St. – South Wall Exterior

112-114 Black Seam Tar 936 E. 3rd St. – South Wall Exterior

115-117 Black Tar Paper 936 E. 3rd St. – Shop Roof (Pitched Roofs)

118-120 Exterior Stucco 927-929 E. 3rd St. – Oil Storage Exterior

121-123 Multiple Layers Roofing 308-310 Breeden St./1001 E. 3rd St. – Roof

127-129 Rolled Cap Sheet & Felt 308-310 Breeden St./1001 E. 3rd St. – Roof




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5.0 LEAD PAINT

5.1 XRF Testing Results

Lead XRF testing was performed in the scope of work areas to identify components containing lead

above the established action level or threshold of 1.0 milligram per square centimeter (mg/cm2). In

addition, the current condition of the tested paint/coating was noted. Ceramic tile was also tested to

identify the presence of lead in the glazing.

Prior to the start of testing and at the end of the test period (or 4 hours, whichever is less), Altec

recorded pre- and post-calibration readings on a calibration form. Altec recorded the XRF readings

on data sheets which are presented in Appendix E. Please note that many additional confirmatory

and/or quality assurance readings were taken during the inspection, but listing each of the additional

tests/readings along with the locations, material assessment, etc. would require an exhaustive effort

that was not part of the scope of work.

None of the components tested were found to be above 1.0 mg/cm2 by the XRF analyzer. CDPH3,

EPA and HUD define LBP as paint or other surface coating that contains any amount of lead equal

to or in excess of 1.0 mg/cm2 or more than 0.5% by weight. It must be understood that

painted/coated materials that contain lead at concentrations of less than 1.0 mg/cm2 still contain

lead, but these lesser amounts have been determined to be “safe” by CDPH, EPA and HUD.

Cal/OSHA does not recognize the use of XRF devices and the units of measure obtained through

the use of XRF (mg/cm2). Cal/OSHA considers concentrations below 600 ppm “safe” and requires

bulk paint chip sampling and/or air sampling for exposure assessment purposes to determine

regulatory compliance for worker protection. This information should be provided to the

renovation/demolition contractor. See Section 5.2 for additional information.

A complete list of all test locations can be found within the XRF data sheet which is provided in

Appendix E.

5.2 Paint Chip Sample Collection and Laboratory Analysis

Bulk paint chip sampling and employee exposure assessment are activities/obligations for the

demolition/renovation contractor as part of their compliance with Cal/OSHA worker protection

regulations.

Solely to assist the renovation/demolition contractor in complying with Cal/OSHA worker

protection requirements, Altec collected one or more bulk sample from damaged or deteriorated

painted components to obtain lead analysis so that the concentrations can be compared to

Cal/OSHA’s lead paint threshold of 0.06% dry weight (or 600 ppm). These samples were collected

for damaged or deteriorated painted components that were found to contain lead concentrations

below the positive threshold (either 1.0 mg/cm2 or as established by local jurisdiction).

Cal/OSHA (CCR Title 8 Section 1532.1 (d)(5)(B)) indicates that surface coatings or materials that

contain lead at concentrations below 0.06% dry weight (or 600 ppm) do not constitute a health

3 CDPH (Title 17 CCR Division 1, Chapter 8, Section 35033).




Page 13

hazard to employees engaged in typical lead-related construction work. This means that

construction work involving materials below 0.06% or 600 ppm of lead can be performed without

the customary employee protection provisions (respiratory protection, protective clothing, clothing

change areas, hand washing facilities, biological monitoring, and training), which are otherwise

necessary until employee exposure monitoring shows that airborne lead concentrations are shown to

be below the lead PEL of 50 mg/m3. When construction work involves materials containing lead in

concentration at or above 0.06% or 600 ppm, Cal/OSHA requires that employers must first perform

exposure determinations to document that employee exposures are below the lead PEL before

employees can perform such work without the worker protection measures.

The samples were submitted to a National Lead Laboratory Accreditation Program (NLLAP)

accredited laboratory for analysis by EPA 600/R-93/200 Preparation Modified, EPA Method 7000B

Analysis Modified (which is equivalent to ASTM E 1729 – Standard Practice for Field Collection

of Dried Paint Samples for Subsequent Lead Determination).

Laboratory QuanTEM Laboratories, 2033 Heritage Park Drive, Oklahoma City, OK

A total of 2 samples were collected and submitted for laboratory analysis. The bulk sample results

are presented in the following table:

Table 4 - Bulk Sample Results (Lead)

Bulk

Sample

No.

Building

Component Location Substrate

Visible

Paint

Color

Lead Results

% by

weight

mg/kg or

ppm4

1 Exterior Walls/Fascia 936 E. 3rd Street Wood Grey 0.193% 1,930 ppm

2 Exterior Walls/Fascia/Eaves

308-310 Breeden

Street/1001 E. 3rd

Street

Metal/Wood Grey 0.00742% 74.2 ppm

Note: Altec only collected bulk samples of the exterior paint that was in damaged condition. Other

intact paints may contain lead in concentrations above 600 ppm. Cal/OSHA exposure assessment

requirements apply.

If the collected paint chip samples contain lead in concentrations greater than 50 mg/kg; STLC and

TCLP analysis will be required for waste characterization purposes. In addition, any paint chip

waste generated by stabilization efforts (loose and flaking paint scraping) must be contained and

profiled properly for transportation and disposal.

Appendix B contains supplemental information on the sampling strategies, protocols, and

limitations associated with the lead testing/sampling that was performed. See Appendix E for the

certified analytical reports.

4 milligrams per kilogram (mg/kg) = parts per million (ppm)

Appendix A

Common Acronyms/Definitions

Common Acronyms/Definitions

ASBESTOS

AIHA – American Industrial Hygiene Association

The Asbestos Hazard Emergency Response Act (AHERA) – Requires local education agencies to

conduct inspections, develop management plans, and design or conduct response actions with respect to

the presence of asbestos-containing materials in school buildings. AHERA also requires states to develop

model accreditation plans for persons who perform asbestos inspections, develop management control

plans, and design or conduct response actions.

AHERA Building Inspector - A person who has successfully completed the training requirements for a

building inspector established by EPA Asbestos Model Accreditation Plan; Interim Final Rule (40 CFR

Part 763, Appendix C to Subpart E, I.B.3) and whose certification is current.

AHERA Project Designer - A person who has successfully completed the training requirements for an

asbestos abatement project designer established by EPA regulations (40 CFR 763.90(g)) and whose

certification is current.

AHERA School Rules – Requires all public school districts and private schools known as local education

agencies or LEAs, to inspect all school buildings for both friable and non-friable asbestos; to develop

plans to manage asbestos in schools; and to carry out plans in a timely fashion. This rule also provides an

opportunity for parents, teachers, and other school employees to become familiar with and involved in

their school’s asbestos management program. School officials are required to notify parent, teacher, and

employee groups about asbestos-related activities.

Asbestos School Hazard Abatement Reauthorization Act (ASHARA) – passed in 1990, required

accreditation of personnel working on asbestos activities in schools and public and commercial buildings.

Asbestos Containing Material (ACM) - any material containing more than one percent asbestos.

Common examples of ACM include but are not limited to: pipe and boiler insulation, sprayed on

fireproofing, troweled on acoustical plaster, floor tile and mastic, floor linoleum, transite shingles, roofing

materials, wall and ceiling plaster, ceiling tiles, and gasket materials.

Asbestos Awareness Training is provided for employees who conduct asbestos work that is not

considered an asbestos project or is excluded from asbestos worker certification.

Asbestos Project includes the construction, demolition, repair, remodeling, maintenance, or renovation of

any public or private building or structure, mechanical piping equipment or system involving the

demolition, removal, encapsulation, salvage, or disposal of material or outdoor activity releasing or likely

to release asbestos fibers into the air.

Asbestos Survey is an inspection by certified inspectors which is conducted to determine whether

materials to be worked on or removed contain asbestos.

Asbestos-Containing Material (ACM) – Any material containing more than 1% asbestos.

Asbestos Building Inspection - A written report describing an inspection using the procedures contained

in EPA regulations (40 CFR 763,86) to determine whether materials or structures to be worked on,

renovated, removed, or demolished (including materials on the outside of structures) contain asbestos.

Building Component - Any element of a building that may be painted or have dust on its surface, e.g.

walls, stair treads, floors, railings, doors, window sills, etc.

CERCLA - The Comprehensive Environmental Response Compensation and Liability Act which is alsoo

known as the "Superfund."

CFR – Code of Federal Regulations.

Chain of Custody Record - Legal documentation that follows samples from collection to the laboratory

indicating who has been in possession of the samples.

Class I Asbestos Work – One of the four classes of activities covered in the Construction Standard.

Refers to activities involving the removal of TSI and sprayed-on, troweled-on or otherwise applied

surfacing ACM and PACM.

Class II Asbestos Work – One of the four classes of activities covered in the Construction standard.

Refers to activities involving the removal of ACM, which is not TSI, or surfacing ACM or PACM. This

includes, but is not limited to, the removal of asbestos-containing wallboard, floor tile and sheeting,

roofing and siding shingles, and construction mastics.

Class III Asbestos Work – One of the four classes of activities covered in the Construction standard.

Refers to repair and maintenance operations, which are likely to “disturb” ACM or PACM, including TSI

and surfacing ACM.

Class IV Asbestos Work – One of the four classes of activities covered in the Construction standard.

Refers to maintenance and custodial construction activities during which employees contact but do not

“disturb” ACM or PACM, and activities to clean up dust, waste, and debris resulting from Class I, II and

III activities. This includes dusting surfaces, vacuuming carpets, mopping floors, cleaning up ACM or

PACM materials from thermal system insulation or surfacing ACM/PACM. Incidental disturbance could

include activities such as changing a battery in a smoke detector attached to a ceiling containing ACM or

PACM; polishing floors containing asbestos, and changing a light bulb in a fixture attached to an asbestos

containing ceiling.

Competent Person – One who is capable of identifying existing and predictable hazards in the

surroundings or working conditions, which are unsanitary, hazardous, or dangerous to employees, and

who has authorization to take prompt corrective measures to eliminate them (29 CFR 1926.32 (f)). Also,

the "competent person" must be designated by the employer (29 CFR 1926.20(b)(2)). OSHA notes that

this "competency" is independent of the training required to be an asbestos competent person.

"Competency" as well as training is required. Thus, a "competent person" is not merely someone with a

specified level of training but connotes a high level of knowledge of worksite safety and health issues as

well.

Competent Person Training Requirements – Asbestos

One who is capable of identifying existing asbestos hazards in the workplace and selecting the

appropriate control strategy for asbestos exposure, and has the authority to take prompt corrective

measures to eliminate them, as specified in 29 CFR 1926.32(f). For Class I and Class II work, the

“competent person” must take a course (or an equivalent course), which meets the criteria of EPA's

Model Accreditation Plan (40 CFR 763) for supervisor. For Class III and Class IV work, the “competent

person” must be trained in a manner consistent with EPA requirements for training of local education

agency operations and maintenance staff as set forth at 40 CFR 763.92 (a)(2).

"Disturbance,” in Reference to Asbestos and Class II Work - Activities that disrupt the matrix of

ACM or PACM, crumble or pulverize ACM or PACM, or generate visible debris from ACM or PACM.

Operations may include drilling, abrading, cutting a hole, cable pulling, crawling through tunnels, or

attics and spaces above the ceiling where asbestos is actively disturbed or asbestos-containing debris is

actively disturbed.

EPA - The United States Environmental Protection Agency

Friable Asbestos Material - Any material containing more than one percent asbestos, as determined

using the method specified in Appendix A, subpart F 40 CFR part 763, section 1, Polarized Light

Microscopy, that when dry, can be crumbled, pulverized, or reduced to powder by hand pressure. If the

asbestos content is less than 10 percent as determined by a method other than point counting by polarized

light microscopy (PLM), verify the asbestos by point counting using PLM.

Glovebag - A sealed compartment with attached inner gloves used for the handling of asbestos-

containing materials.

HEPA, High-Efficiency Particulate Air (Filter) - A filter capable of trapping and retaining at least

99.97 percent of all mono-dispersed particles of 0.3 micrometers in diameter.

Intact Asbestos - means that the ACM has not crumbled, been pulverized, or otherwise deteriorated so

that the asbestos is no longer likely to be bound with its matrix. Friable ACM that is disturbed is

presumed to be no longer intact.

LF - Linear feet

Lockout/Tagout – Refers to specific practices and procedures to safeguard employees from the

unexpected energization or startup of machinery and equipment, or the release of hazardous energy

during service or maintenance activities.

Negative pressure enclosure - means any enclosure of an asbestos abatement project area where the air

pressure outside the enclosure is greater than the air pressure inside the enclosure and the air inside the

enclosure is changed at least four times an hour by exhausting it through a HEPA filter.

NESHAP - The National Emission Standard for Hazardous Air Pollutants found in Title 40 CFR Part 61

promulgated under Section 112 of the Clean Air Act.

NIOSH - National Institute for Occupational Safety and Health

NIST - National Institute of Standards and Technology

NVLAP - National Voluntary Laboratory Accreditation Program

OSHA - Occupational Safety & Health Administration

Owner - The legal entity, including a lessee, which exercises control over management and record

keeping functions relating to a building and/or facility in which the abatement activities described in this

document take place.

Owners Representative - A person authorized by the Owner to act on the Owners behalf.

PACM (Presumed Asbestos Containing Material) – PACM is limited to thermal system insulation and

sprayed or troweled on, or otherwise applied surfacing material in buildings constructed no later than

1980. The material is "presumed" to contain asbestos unless it is demonstrated, in accordance with the

standard, that PACM does not contain asbestos. Asphalt and vinyl flooring material installed no later than

1980 must also be considered as asbestos containing unless the employer determines them to be asbestos

free.

Parts per million by weight, ppm - equivalent to μg/gram (10,000 ppm = 1 percent).

PLM - Polarized light microscopy, as defined in Appendix A, subpart F, 40 CFR part 763, section 1

RACM, Regulated Asbestos-Containing Material - RACM means (a) Friable asbestos material, (b)

Category I nonfriable ACM that has become friable, (c) Category I nonfriable ACM that will be or has

been subjected to sanding, grinding, cutting, or abrading, or (d) Category II nonfriable ACM that has a

high probability of becoming or has become crumbled, pulverized, or reduced to powder by the forces

expected to act on the material in the course of demolition or renovation operations regulated by the

Asbestos NESHAP.

RCRA - Resource Conservation and Recovery Act

Removal - All operations where ACM and/or PACM is taken out or stripped from structures or substrate,

and includes demolition operations.

SF, Sq. Ft., ft² - Square foot/feet - One square foot is equal to an area that has a length of one foot (12

inches) and a width of one foot (12 inches).

Surfacing ACM – Material that is sprayed, troweled-on, or otherwise applied to surfaces (such as

acoustical plaster on ceilings and fireproofing materials on structural members, or other materials on

surfaces for acoustical, fireproofing, and other purposes), and that contains more than 1% asbestos.

Suspect ACM - Material that is suspected of containing asbestos that has not been sampled and analyzed

for asbestos content.

Thermal System Insulation (TSI) – ACM applied to pipes, fittings, boilers, breeching, tanks, ducts or

other structural components to prevent heat loss or gain.

TSCA - Toxic Substances Control Act

Visible Emissions - Any emissions, which are visually detectable without the aid of instruments, coming

from RACM or asbestos- containing waste material, or from any asbestos milling, manufacturing, or

fabricating operation.

LEAD

Building Component - Any element of a building that may be painted or have dust on its surface, e.g.

walls, stair treads, floors, railings, doors, window sills, etc.

CERCLA - The Comprehensive Environmental Response Compensation and Liability Act which is alsoo

known as the "Superfund."

CFR – Code of Federal Regulations.

Chain of Custody Record - Legal documentation that follows samples from collection to the laboratory

indicating who has been in possession of the samples.

Cleaning - The process of using a HEPA vacuum and wet cleaning agents to remove leaded dust; the

process includes removal of bulk debris from the work area. OSHA prohibits the use of compressed air to

clean lead-contaminated dust from a surface.

Clearance Examination - Clearance is performed after hazard reduction, rehabilitation or maintenance

activities to determine if a unit is safe for occupancy. It involves a visual assessment, analysis of dust

and/or soil samples, and preparation of report. A certified risk assessor, paint inspector, or clearance

technician (independent from entity/individual conducting paint stabilization or hazard reduction)

conducts clearance.

Complete abatement - Abatement of all lead-based paint inside and outside a dwelling or building and

reduction of any lead-contaminated dust or soil hazards. All of these strategies require preparation;

cleanup; waste disposal; post-abatement clearance testing; recordkeeping; and, if applicable, reevaluation

and on-going monitoring.

Delamination – Separation of materials as a result of water damage, abrasion, sanding, drilling, sawing,

gouging.

Deteriorated Lead-Based Paint - Any lead-based paint coating on a damaged or deteriorated surface or

fixture, or any interior or exterior lead-based paint that is peeling, chipping, blistering, flaking, worn,

chalking, alligatoring, cracking, or otherwise becoming separated from the substrate.

Encapsulation - Any covering or coating that acts as a barrier between lead-based paint and the

environment, the durability of which relies on adhesion and the integrity of the existing bonds between

multiple layers of paint and between the substrate. See also Enclosure.

Enclosure - The use of rigid, durable construction materials that are mechanically fastened to the

substrate to act as a barrier between the lead-based paint and the environment.

EPA - The United States Environmental Protection Agency

HEPA, High-Efficiency Particulate Air (Filter) - A filter capable of trapping and retaining at least

99.97 percent of all mono-dispersed particles of 0.3 micrometers in diameter.

HUD – US Department of Housing and Urban Development

Lead Abatement - A measure or set of measures designed to permanently (i.e. 20 or more years)

eliminate lead based paint hazards or lead-based paint. Abatement strategies include the removal of lead-

based paint, enclosure, encapsulation, replacement of building components coated with lead-based paint,

removal of lead-contaminated dust, and removal of lead-contaminated soil or overlaying of soil with a

durable covering such as asphalt (grass and sod are considered interim control measures). All of these

strategies require preparation; cleanup; waste disposal; post abatement clearance testing; record keeping;

and, if applicable, monitoring.

Lead-Based Paint, LBP - Any paint, varnish, shellac, or other coating that contains lead equal to or

greater than 1.0 mg/cm² as measured by XRF or laboratory analysis, or 0.5 percent by dry weight (5,000

mg/g, 5,000 ppm, or 5,000 mg/kg) as measured by laboratory analysis.

Lead-Based Paint Hazards - Housing conditions that cause human exposure to unsafe levels of lead

from paint. These conditions include deteriorated lead-based paint; friction, impact or chewable painted

surfaces; lead-contaminated dust; or lead-contaminated soil.

Lead-Based Paint Hazard Control - Activities to control and eliminate lead-based paint hazards,

including interim controls, abatement, and complete abatement.

LF - Linear feet

Lockout/Tagout – Refers to specific practices and procedures to safeguard employees from the

unexpected energization or startup of machinery and equipment, or the release of hazardous energy

during service or maintenance activities.

Maintenance - Work intended to maintain adequate living conditions in a dwelling, which has the

potential to disturb lead-based paint or paint that is suspected of being lead-based.

Microgram, μg - A microgram is 1/1000th of a milligram (or one millionth of a gram). To put this unit

into perspective, a penny weighs 2 grams. To get a microgram, you would need to divide the penny into 2

million pieces. A microgram is one of those two million pieces.

Micrograms per deciliter, μg/dL - used to measure the level of lead in children’s blood to establish

whether the intervention is needed. A deciliter (1/10th of liter) is a little less than half a cup. As noted

above, a microgram is the same weight as one penny divided into two million parts.

Milligrams per square centimeter, mg/cm² - used for paint by XRF machines.

Monitoring - Surveillance to determine (1) that known or suspected lead-based paint is not deteriorating,

(2) that lead-based paint hazard controls, such as paint stabilization, enclosure, or encapsulation have not

failed, (3) that structural problems do not threaten the integrity of hazard controls or of known or

suspected.

Negative pressure enclosure - means any enclosure of an asbestos abatement project area where the air

pressure outside the enclosure is greater than the air pressure inside the enclosure and the air inside the

enclosure is changed at least four times an hour by exhausting it through a HEPA filter.

NIOSH - National Institute for Occupational Safety and Health

NIST - National Institute of Standards and Technology

NVLAP - National Voluntary Laboratory Accreditation Program

OSHA - Occupational Safety & Health Administration

Owner - The legal entity, including a lessee, which exercises control over management and record

keeping functions relating to a building and/or facility in which the abatement activities described in this

document take place.

Owners Representative - A person authorized by the Owner to act on the Owners behalf.

Paint Film Stabilization - An interim control method that stabilizes painted surfaces and addressed the

underlying cause of deterioration. Steps include repairing defective surfaces, wet scraping, priming, and

repainting surfaces coated with deteriorated lead-based paint; paint film stabilization includes cleanup and

clearance.

Paint Removal - An abatement strategy that entails the removal of lead-based paint from surfaces. For

lead hazard control work, this can mean using chemicals, heat guns below 1,000°F, and certain abrasive

methods. Open flame burning, open abrasive blasting, sandblasting, water blasting, and extensive dry

scraping are prohibited paint removal methods.

Paint Testing - Testing of specific surfaces, by XRF (x-ray fluorescence) or lab analysis, to determine the

lead content of these surfaces, performed by a certified lead-based paint inspector or certified risk

assessor.

Parts per million by weight, ppm - equivalent to μg/gram (10,000 ppm = 1 percent). Used to measure

lead in paint and soil.

PCS - Performance Characteristic Sheet (XRF Device)

Percent - percent by weight, used usually for lead-based paint (1 percent = 10,000 μg/gram.

Positive threshold (lead) - contains lead equal to or greater than 1.0 mg/cm² as measured by XRF or

laboratory analysis, or 0.5 percent by dry weight (5,000 mg/g, 5,000 ppm, or 5,000 mg/kg) as measured

by laboratory analysis. If in Los Angeles County - lead equal to or greater than 0.7 mg/cm² as measured

by XRF or laboratory analysis, or 0.06 percent by dry weight or 600 ppm.

RCRA - Resource Conservation and Recovery Act

Removal - All operations where ACM and/or PACM is taken out or stripped from structures or substrate,

and includes demolition operations.

Replacement - Replacement of existing features can be an appropriate abatement technique if the feature

is deteriorated beyond repair or if the feature is of minor significance.

Risk Assessment - A comprehensive evaluation for lead-based paint hazards that includes paint testing,

dust and soil sampling, and a visual evaluation. The assessment report identifies lead hazards and

appropriate lead hazard reduction methods. A certified risk assessor must conduct the assessment.

SF, Sq. Ft., ft² - Square foot/feet - One square foot is equal to an area that has a length of one foot (12

inches) and a width of one foot (12 inches).

Soluble Threshold Limit Concentration (STLC) - Laboratory analysis that determines the soluble

portion of the analytes in a sample. This procedure is used when determining the hazardous waste

characterization under California State regulations defined in Title 22 of the California Code of

Regulations (CCR). The STLC is a waste extraction test performed to determine if there are toxic

concentrations of lead in the leachate formed from the specific material tested. This analysis determines

the amount of lead that is soluble in the Waste Extraction Test (WET) leachate. This WET procedure is

used for solid samples or for samples containing

weight of a 0.2M sodium citrate buffer for 48 hours. This leachate is then analyzed to determine the

soluble concentrations.

Total Threshold Limit Concentration (TTLC) – laboratory analytical test that determines the total

concentration of lead (or other target analyte) in a sample.

Toxic Characteristic Leaching Procedure (TCLP) – Laboratory analysis that determines the soluble

portion of the analytes in a sample. This is a federal guideline and differs from the State in several ways.

The alkalinity of the sample must first be determined in order to know which of two different extraction

fluids should be used for the procedure. Samples with a low alkalinity use extraction fluid #1 which is a

sodium acetate solution with a pH of 4.93. Samples with a high alkalinity use extraction fluid #2 which is

a dilute acetic acid solution with pH of 2.8. The sample is then tumbled in the appropriate extraction fluid

for 18 hours.

TSCA - Toxic Substances Control Act

Visual Assessment - A visual evaluation of interior and exterior painted surfaces to identify specific

conditions that contribute to lead-based paint hazards. A certified risk inspector/assessor trained in visual

assessment performs the assessment.

XRF – X-ray fluorescence device

Appendix B

Supplemental Information (Sampling Overview, Strategy, Protocol, Limitations)

ASBESTOS

Asbestos Definition

Asbestos is a term used to describe six different naturally occurring mineral fibers found in certain rock

formations. Asbestos fibers can be found in relatively low levels nearly everywhere in the environment.

Prior to 1980, asbestos mineral fibers were used extensively as matrix components during the

manufacturing of building materials and products. Asbestos became a popular building material

component due to the strength of the fibers, their resistance to heat and corrosion and their tremendous

insulation and acoustic properties. Due to the fibers small size and weight, once airborne (during

demolition or after damage), they can remain suspended for many hours. Airborne releases pose a

potential exposure condition because the inhalation of airborne asbestos fibers can cause serious health

problems including cancer.

Asbestos Regulatory Overview

In an effort to summarize California’s development of asbestos regulations, it is necessary to briefly

describe essential state regulations enacted to identify, control and prevent exposure to toxic chemicals in

the business environment. Requirements imposed in 1986 by the State of California within Proposition 65

(Safe Drinking Water and Toxics Enforcement Act) established criteria for the listing and publication of

chemicals known to cause cancer or reproductive toxicity. A portion of Proposition 65 imposes

prohibitions regarding exposure to regulated materials, toxins and listed chemicals (of which asbestos is

included) without prior warnings to inhabitants of a building by a property owner or property manager.

The EPA has issued an interim final rule revision of its Model Accreditation Plan (MAP) to clarify the

types of training requirements necessary for asbestos-related work in schools. California’s Connelly Bill

(Assembly Bill 2588 - The Toxics Hot Spots Act) which was passed in 1987 requires that the California

Air Resources Board develop a list of toxic air contaminants for which emissions must be reported and

regulated. The Connelly Bill extended requirements for notification regarding the location, condition,

status, and health risks associated with ACM in areas of public, private and commercial building which

are accessible to the building’s occupants. These requirements extend to employees, tenants, maintenance

personnel; independent contractors and all other performing work in the building or facility. In 1986,

Congress enacted the Asbestos Hazard Emergency Response Act (AHERA or TSCA Title II), which

mandated a regulatory program to address asbestos hazards in schools. In 1990, Congress enacted

Asbestos School Hazard Abatement Reauthorization Act (ASHARA) that amended AHERA to extend

some of the training, accreditation requirements, and sampling protocol to persons performing asbestos-

related work in public and commercial building.

The key elements to AHERA/ASHARA regulations require the development of an Operations and

Maintenance (O&M) Program if friable ACM (or non-friable ACM which will become friable) is present

in a building.

Asbestos Sampling Protocol

The sampling protocol established within AHERA (extended to commercial buildings by ASHARA) was

used to determine the required number of samples for this survey based on the type, number and location

of homogeneous building materials. AHERA protocol was used to determine homogeneous areas of

construction in the building. Three forms of asbestos are typically found in buildings: (1) sprayed- or

toweled-on surfacing materials, (2) insulation on pipes, boilers and other mechanical equipment, and (3)

miscellaneous forms such as floor tile, ceiling tile, roofing materials, wallboards, window glazing, etc.

AHERA recommends the collection of a minimum of nine (9) samples for each suspect asbestos-

containing material (ACM). However, the minimum numbers of samples required by AHERA for

sampling purposes are listed in the following table:

Altec Sampling Protocol

Type of Material Estimated Quantity Required Samples

Sprayed or Troweled-on Surfacing Material >5,000 ft2 7

Sprayed or Troweled-on Surfacing Material 1,000-5,000 ft2 5

Sprayed or Troweled-on Surfacing Material

polarized light using microscopes with a special optical lenspiece5. Optical characteristics of the fibrous

material reveal the mineralogy of the fibers. Asbestos fiber content is estimated by optically comparing

the quantity of non-asbestos material to asbestos fibers. The lower limit of reliable detection using PLM is

1%. Samples that contain more than 1% asbestos fibers are reported in percent ranges. Samples that

contain asbestos fibers in a concentration lower than 1% are reported as “trace” or “

Asbestos Limitations

The work that was performed during this inspection was done at the request of the client or the client’s

representative. The investigation was completed in a non-destructive manner. No repairs of the materials

sampled were performed. If the building or buildings were occupied during the inspection, additional

inspection may be necessary after the building(s) are vacant but prior demolition and renovation to ensure

that there are no additional suspect ACMs present.

As previously mentioned, suspect ACMs may exist in inaccessible or hidden areas of the building(s) and

these materials may not have been identified or sampled such as but not limited to thermal system

insulation (TSI), ceiling or wall insulation, flooring materials below sub-floors, and Transite™ pipes. The

quantifications of the suspect ACMs are estimates made at the time of sampling and should be verified by

perspective asbestos abatement contractors to determine exact quantities and the accessibility of the

specific materials.

The opinions and conclusions presented here are based on field observations and are consistent with

practices and actions of consulting professionals in the asbestos and industrial hygiene fields.

LEAD

Overview

Lead in painted and/or coated materials can cause potential health problems for occupants. Lead is highly

toxic and exposure to it can affect every system of the human body, it is often found in painted and coated

surfaces. The groups most at risk to lead exposure are fetuses, infants and children under the age of 6;

however, older children and adults also suffer severe damage from lead exposures. Most lead-poisoned

children are exposed in their homes. At high levels, exposure to lead can cause death. At low levels, lead

exposure affects children’s developing brains and nervous systems, causing reductions in IQ, attention

span, learning disabilities, hyperactivity and behavioral problems. The vast majority of childhood lead

poisoning cases go undiagnosed and untreated because most poisoned children have no “obvious”

symptoms. Most exposures occur through typical hand to mouth contact (ingestion) from lead dust

accumulations on floors, window sills and/or from contaminated soil in play areas. Performing a lead

inspection (or a lead risk assessment) and correcting lead hazards are essential steps in maintaining a lead

safe space.

Lead Paint Testing Protocol

The lead testing was patterned after the lead-based paint inspection protocol in Chapter 7 of the EPA

Housing and Urban Development (HUD-2012) Guidelines for the Evaluation and Control of Lead-Based

Paint Hazards in Housing. It was not Altec’s intention to conduct an evaluation of lead-based paint

hazards in complete accordance with HUD guidelines because the tested structures will be renovated or

demolished. HUD lead inspection/risk assessment protocol generally requires a very extensive sampling

strategy and documentation that is beyond the scope of work established for this project.

Altec used a portable hand held XRF spectrum analyzer to test the painted/coated building components.

HUD recommends that lead concentrations be reported in mg/cm2, which essentially is a recommendation

for the use of XRF analyzers. The reasoning behind their recommendation is that the results reported in

mg/cm2 do not change based on the number of layers of non-lead paint or coatings present at the test

location. Results that are reported in weight percent or parts per million change depending on the number

of layers of non-lead paint/coating and based on how much, if any, substrate is removed and included

within the sample. In addition, XRF results can usually be obtained without damaging the painted/coated

surface.

Within each individual interior space or room of the facility, at least one representative surface of each

unique painted/coated component (called a testing combination by HUD) was tested. At least 4 readings

are taken for the walls (each from a different wall) within a room/area. In most cases, duplicate/multiple

XRF readings were taken of similar testing combinations within a single space/room. It is not uncommon

to have an excess of 50 components tested per warehouse, shop area or mechanical space at industrial

facilities. Exterior surfaces/components associated with each structure and the equipment racks, tanks,

pipes, supports, etc. on or near the structure were tested in the same manner. The individual XRF readings

were entered into an electronic XRF data sheet, along with information regarding the room/space, floor,

test location, component, substrate, visible color and whether the paint appeared intact.

Painted surfaces with XRF readings of 1.0 mg/cm2 or above are considered positive; other jurisdictions

have stabled more conservative positive thresholds for lead based paint such as in Los Angeles County

where the positive threshold is 0.7 mg/cm2. It must be understood that painted/coated materials that

contain lead at concentrations of less than 1.0 mg/cm2 (or the applicable positive threshold) still contain

lead, but these lesser amounts have been determined to be “safe” by EPA and HUD, CDPH or other

regulatory agency. Cal/OSHA, however, does not consider these concentrations “safe”, and requires bulk

sampling and/or air sampling for exposure assessment purposes to determine regulatory compliance for

general industry or construction work.

It should be noted that Cal/OSHA regulations require that any renovation or demolition work performed

on components containing any detectable lead (typically above 600 ppm) must be performed by lead

certified workers until an exposure assessment establishes that the exposures are below the lead action

level in air.

Lead testing was performed using a RMD LPA-1 XRF spectrum analyzer; the Performance Characteristic

Sheet (PCS) for the model unit is provided within the Appendix section of this report. The device was

operated in accordance with the manufacturer’s instructions in addition to the procedures described in

Chapter 7 of the HUD Guidelines. The unit was operated in the “Quick Mode”. The exposure duration

required for each result was based on the actual reading relative to the designated action level, the age of

the radioactive source and the substrate on which the reading was taken. When using the an XRF analyzer

in the “Quick Mode”, substrate corrections are not necessary if the readings are taken on brick, concrete,

drywall, metal, plaster, stucco or wood.

The XRF device’s calibration was verified according to the manufacturer’s specifications in compliance

with the LPA-1 PCS. Altec performed field calibration checks at the beginning of the inspection, at least

once per 4 hours of inspection work and once again before the XRF analyzer was turned off or was

moved offsite to a second inspection location. A calibration check consists of three or more readings

taken using NIST Standard Reference Material (SRM) with paint film having a lead concentration nearest

to 1.0 mg/cm2.

Individual XRF readings are recorded on XRF Data Sheets. Any future changes in action levels by

regulating agencies may affect the classification of results. If such action level changes occur the XRF

results can be reinterpreted and new classifications can be made. No additional XRF testing is necessary.

HUD and EPA recommend that lead concentrations be reported in mg/cm2, which essentially is a

recommendation for the use of XRF analyzers. The reasoning behind their recommendation is that the

results reported in mg/cm2 do not change based on the number of layers of non-lead paint or coatings

present at the test location. Results reported in parts per million or weight percent change depending on

the number of layers of non-lead paint/coating and based on how much, if any, substrate is removed and

included within the sample. In addition, XRF results can usually be obtained without damaging the

painted/coated surface.

Use of XRF Device

In accordance with the HUD and EPA recommendations, lead testing was performed using an XRF

analyzer. The specific unit used was a RMD LPA-1 and its PCS is provided as an appendix to this report.

The device was operated in accordance with the manufacturer’s instructions in addition to the procedures

described in Chapter 7 of the HUD Guidelines. The unit was operated in the Lead-In-Paint K&L Variable

Reading Time Mode. The exposure duration required for each result was based on the actual reading

relative to the designated action level, the age of the radioactive source and the substrate on which the

reading was taken. When using the an XRF analyzer in the Lead-In-Paint K&L Variable Reading Time

Mode, substrate corrections are not necessary if the readings are taken on brick, concrete, drywall, metal,

plaster, stucco or wood.

The XRF device’s calibration was verified according to the manufacturer’s specifications in compliance

with the PCS developed and approved for the specific instrument.

Altec performed field calibration checks at the beginning of the inspection, at least once per 4 hours of

inspection work and once again before the XRF analyzer was turned off or was moved to a second

inspection location. A calibration check consists of three or more readings taken using NIST Standard

Reference Material (SRM) with paint film having a lead concentration nearest to 1.0 mg/cm2.

Readings from the instrument produce a 95% confidence level that the reading accurately reflects the

actual concentration of lead in the tested surfaces, relative to the 1.0 mg/cm2 action level.

Lead Bulk Samples

If included in the scope of work, Altec collected bulk samples from the tested paint/coatings to assist in

future construction planning. Components are first grouped into homogenous groupings that appear to

have a similar function, construction and painting history. Representative samples are usually collected

only for exterior components that tested below the positive threshold (either above 1.0 mg/cm2 or above

0.7 mg/cm2) by the XRF.

CCR Title 8 Section 1531 (d)(5)(B) indicates that surface coatings or materials that contain lead at

concentrations below 0.06% dry weight (or 600 ppm) do not constitute a health hazard to employees

engaged in typical lead-related construction work. This means that Cal/OSHA considered that

construction work (demolition of structures, manual scraping, and manual sanding and a few additional

tasks) involving materials below 0.06% or 600 ppm of lead can be performed without the customary

employee protection measures (respiratory protection, protective clothing, clothing change areas, hand

washing facilities, biological monitoring, and training), which are otherwise necessary until employee

exposure monitoring shows that airborne lead concentrations are shown to be below the lead PEL of 50

mg/m3.

When construction work (involving the tasks described above) involves materials containing lead in

concentration at or above 0.06% or 600 ppm, Cal/OSHA requires that employers must first perform a

negative exposure determination to prove that employee exposures are below the lead PEL before

employees can perform such work without the customary protection measures. In these situations,

employee protection measures must be used until the exposure assessment results are obtained and

confirm exposures are below the lead PEL.

In some instances, the collection of bulk samples is not practical. Bulk samples are not routinely collected

inside structures that are occupied, from interior walls, interior cabinets or floor tile, on

machinery/equipment such as CNC machines, lathes, drill presses, grinders, spray booths, resin booths,

electrical boxes and panels, storage racks, sand blasters, dust collector, scrubbers, and other machinery

which has a thin layer of paint because it would require removal of a large surface area to obtain the

minimum weight (5 grams) required for the bulk sample. Sampling these components would cause

significant cosmetic damage. Also, bulk samples are not routinely collected for powder-coated metal

surfaces because paint removal could damage the integrity of the coating or from ceramic tile which

would damage the integrity of the tile.

If performed, bulk sampling is patterned after the protocol established in Appendix 13.2 (Paint Chip

Sampling) of the HUD Guidelines. Each paint chip sample is targeted to weigh at least 5 grams to satisfy

laboratory analytical requirements. Each sample is collected from an area of approximately 2-4 square

inches. Paint is scraped directly off of the substrate and collected into plastic sample baggies or into

plastic centrifuge tubes. Attempts are made to eliminate inclusion of substrate material into the collected

sample. The bulk sample areas are not routinely measured, and therefore, the laboratory provides results

as percent lead (% lead) by weight and ppm.

Making cosmetic repairs to the paint chip sample collection locations is not part of the scope of work. To

avoid cross contamination between sample collection points, the sampling technicians wear disposable

nitrile gloves that were changed between locations and they also cleaned their chisel/scraping tool using

amended water and a disposable cloth after each sample was collected. The used gloves and cleaning

cloths were contained in Ziploc-type baggies and were brought back to Altec’s office for disposal.

Laboratory analysis is performed to obtain the Total Threshold Limit Concentration (TTLC) or total

concentration of lead in the material. The TTLC analysis determines the total concentration of lead (or

other target analyte) in a sample. Samples are analyzed by EPA 7420 for lead. When lead exceeds the

TTLC limit the waste is classified as hazardous. The results of this analysis can be used to determine if

analysis for STLC level is necessary by comparing 10 times the STLC limit to TTLC results. A factor of

ten is necessary to compensate for a 1:10 dilution factor that is present in the STLC analysis but not the

other. If the TTLC result does not exceed 10 times the STLC limit (5.0 mg/L for lead) then normally no

further analysis is required for waste disposal in California.

Lead Soil Assessment/Removal

While the surface coatings and paints on the exteriors of the buildings may or may not contain lead in

concentrations above 1.0 mg/cm2, most of the paint contains lead in detectable concentrations and some

are likely above 600 ppm. Therefore, there may be a possibility that open/bare soil areas along the

foundations could contain elevated lead concentrations.

To ensure proper assessment and documentation of lead concentrations in bare soil along building

foundations, Altec recommends the collection of composite soil samples prior to building demolition.

If performed, soil sampling is patterned after the protocol established in Appendix 13.3 (Collection Soil

Samples for Lead Determination) of the HUD Guidelines. The recommended sampling includes child

play areas, the building dripline around the foundation and non-play areas. The number of samples

depends largely on the size of each area and on the characteristics of the property.

Appendix 13.3 indicates that samples should be collected as follows: The number of subsamples in a

composite soil sample should be no more than ten. Generally, subsamples should be no closer to each

other than 1 ft. (0.3 m) and no farther apart than 3 ft. (1.0 m), but exceptions to this general rule are not

infrequent, due to wide variations in the pattern and extent of bare soil. The location and number of

subsamples depends on the pattern and extent of bare soil in the area being sampled. In a relatively small

contiguous area of, say, 10 sq. ft. (1.0 sq. m), a risk assessor might take one subsample from the center

and one subsample from each of two different directions from the center for a total of three. If the area is

larger, however, it would be reasonable to take more subsamples, more or less evenly spaced to represent

the area. Or, if there is quite a bit of bare soil scattered in a linear pattern along the dripline/foundation

area and extending all around the building, the risk assessor would most likely take 10 subsamples, more

or less evenly spaced.

Soil samples are collected with either a coring tool or a scooping technique. A coring tool is generally a

tube of one-half to one inch in diameter that can be forced into the ground, with a plunger that, after the

tube is removed from the ground, can push out all but the desired amount of soil. That which remains in

the tube is then pushed out into a sample container. The coring method is the preferred method if soil

characteristics allow, because it provides subsamples of uniform and reproducible size. It is not workable,

however, if the soil is loose or sandy.

The scooping method employs a spoon or small scoop or centrifuge tube with which one collects a small

amount of surface soil. Compared to the use of a coring tool, the scooping method may result in bias

toward collecting greater amounts of soil close to the surface relative to below the surface because of the

curvature of the scooping device. This method must be used, however, if the soil is loose or sandy, but

extra care must be taken to assure that the subsamples are of uniform size.

Neither coring nor scooping may be feasible if the soil is frozen or very hard packed. In such cases efforts

must be made to defrost or loosen the soil.

Lead Waste Characterization Samples

If requested by the client and if warranted based on the TTLC-total threshold limit concentration result,

Altec will request additional analysis to determine if the material, once it is removed and becomes a

waste, will be considered a California Hazardous Waste or a federal RCRA Hazardous Waste. This type

of analysis is performed only upon request and approval by the client.

In California, the Soluble Threshold Limit Concentration (STLC) procedure is used when determining the

hazardous waste characterization under California State regulations defined in Title 22 of the California

Code of Regulations (CCR). The STLC is a waste extraction test performed to determine if there are toxic

concentrations of lead in the leachate formed from the specific material tested. Toxic Characteristic

Leaching Procedure (TCLP) is similar to the STLC but involves characterization based on federal EPA

guidelines. The intent of the leachate extraction procedure is to simulate the conditions that may be

present in a landfill where water may pass through the deposited waste and infiltrate through the landfill,

through the underlying soil and carrying the soluble lead into the groundwater.

STLC - Soluble Threshold Limit Concentration

This analysis determines the amount of lead that is soluble in the Waste Extraction Test (WET) leachate.

This WET procedure is used for solid samples or for samples containing

Lead Removal

Demolition activities that will impact lead-based components must be performed by certified/qualified

representatives in compliance with EPA and DOSH rules and regulations. All lead-based paint

components that are deteriorated or peeling must be stabilized in accordance with all applicable

regulations prior to demolition work. A contractor who is trained and holds licenses and insurance in this

field of hazardous materials remediation should conduct any lead related removal work. Exposure

assessments and air monitoring should be conducted in the initial phases of any lead abatement to

determine the amount of personal protection required by workers. Lead components will need to be

properly packaged and characterized utilizing TTLC, STLC and TCLP laboratory analysis as necessary to

determine disposal requirements.

Lead Limitations

This inspection was planned and performed in accordance with Altec training and experience in

performing lead inspections. The inspection was performed to support renovation or demolition of the

building(s). It was NOT performed in accordance with Chapter 7 of the HUD Guidelines for the

Evaluation and Control of Lead-Based Paint Hazards in Housing. Altec’s evaluation of the relative risk of

exposure to lead identified in this survey is based solely on the conditions observed at the time of the site

visit. This project included limited lead testing and not lead risk assessment. Altec cannot be held

responsible for changing conditions that may alter the condition of the lead component surfaces after the

time of the testing or in changes in accepted protocol, methodology or action levels.

Analytical Flow ChartTesting Process for Lead Based

Paint/Coated Components for Disposal in California Landfills

Segregate components and obtain

representative samples of each

(Samples should include at least 200 grams per

material)

Perform TTLC

Analysis by EPA 7420

Perform STLC

Analysis

Perform TCLP

Analysis

Dispose as California Hazardous Waste

(Does Not Require Stabilization)

Dispose as RCRA (federal) Hazardous Waste

(Requires Stabilization)

Dispose as Construction Debris Non-Hazardous

(Any Landfill)

TTLC Result is Below 50 mg/kg

TCLP Result is Below 5.0 mg/L

TTLC Result is Between

350-999 mg/kg

TTLC Result is Above 1000 mg/kg

TTLC Result is between

50 - 349 mg/kg

TCLP Result is Above 5.0 mg/L

STLC Result is Below 5.0 mg/L and TTLC

Result is Below 349 mg/kg)

STLC Result is Above 5.0 mg/L

Dispose as Controlled Trash Lined Landfill

STLC Result is Below 5.0 mg/L and TTLCResult is 350-999 mg/kg

Appendix C

Inspector Certificates

Appendix D

Laboratory Certifications, XRF PCS

AIHA Laboratory Accreditation Programs, LLC 3141 Fairview Park Drive, Suite 777, Falls Church, VA 22042 USA

main +1 703-846-0736 fax +1 703-207-8558 Twitter: @AIHA_LAP_LLC

R3 05/05/2015 Page 1 of 1

September 29, 2017

Laboratory ID: 101352 Jeffrey Miekush QuanTEM Laboratories 2033 Heritage Park Drive Oklahoma City, OK 73120 Dear Mr. Miekush: Congratulations! The AIHA Laboratory Accreditation Programs (AIHA-LAP), LLC’s Analytical Accreditation Board (AAB) has approved QuanTEM Laboratories as an accredited Industrial Hygiene, Environmental Lead and Environmental Microbiology laboratory. Accreditation documentation includes the IHLAP, ELLAP and EMLAP accreditation certificate, scope of accreditation document and a copy of the current AIHA-LAP, LLC license agreement (if your completed agreement is not on file at AIHA-LAP, LLC). The accreditation symbol has been designed for use by all AIHA-LAP, LLC accredited laboratories. If your laboratory chooses to use the symbol in its advertising the laboratory’s accreditation, you must complete and return the AIHA-LAP, LLC license agreement to a Laboratory Accreditation Specialist. Once submitted, an electronic copy of the accreditation symbol will be sent to you. Please inform us if your laboratory does not wish to use the symbol in advertising. Laboratory accreditation shall be maintained by continued compliance with IHLAP, ELLAP and EMLAP requirements (see Policy Modules 2B, 2C, 2D and 6), which includes proficient participation in AIHA-LAP, LLC approved proficiency testing, demonstration of competency, or round robin program as indicated on the AIHA-LAP “Approved PT and Round Robin” webpage, its associated Scope/PT table, and as required in Policy Module 6, for all Fields of Testing (FoTs) for which the laboratory is accredited. An accredited laboratory that wishes to expand into a new FoT must submit an updated accreditation application to AIHA-LAP, LLC for review by the AAB. Any changes in ownership, laboratory location, personnel, FoTs/Methods, or significant procedural changes shall be reported to AIHA-LAP, LLC in writing within twenty (20) business days of the change. The accreditation certificate is the property of AIHA-LAP, LLC and must be returned to us should your laboratory withdraw or be removed from the IHLAP, ELLAP and EMLAP. Again, congratulations. If you have any questions, please contact Lauren Schnack, Senior Specialist, Quality and Accreditation, at (703) 846-0716. Sincerely,

Cheryl O. Morton Managing Director AIHA Laboratory Accreditation Programs, LLC

AIHA Laboratory Accreditation Programs, LLC

acknowledges that

QuanTEM Laboratories 2033 Heritage Park Drive, Oklahoma City, OK 73120

Laboratory ID: 101352 along with all premises from which key activities are performed, as listed above, has fulfilled the requirements of the AIHA Laboratory Accreditation

Programs (AIHA-LAP), LLC accreditation to the ISO/IEC 17025:2005 in

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