B08_Solicitation_WHIS_VC_FInal_Hazardous_Material_Survey_Report_0001.pdf

Rehabilitate, Upgrade, and Expand the Visitor Center to Better Meet Visitor Needs

HAZARDOUS MATERIALS SURVEY REPORT

Whiskeytown National Recreation Area, CA

PMIS # 199335

Prepared for:

National Park Service Whiskeytown Visitor Center

14412 J.F. Kennedy Memorial Drive Whiskeytown, CA 96095

Contract No. 140P8519D0010

Prepared by:

January, 2023

2022-628 Whiskeytown Visitor Center Page i

TABLE OF CONTENTS

Page

EXECUTIVE SUMMARY

ASBESTOS SURVEY

SURVEY METHODOLOGY

ANALYTICAL METHODOLOGY

ASBESTOS FINDINGS

LEAD-BASED PAINT SURVEY

SURVEY METHODOLOGY

ANALYTICAL METHODOLOGY

LEAD-BASED PAINT FINDINGS

LEAD-IN-SOIL SURVEY

SURVEY METHODOLOGY

ANALYTICAL METHODOLOGY

LEAD-IN-SOIL FINDINGS

PCB SURVEY

SURVEY METHODOLOGY

ANALYTICAL METHODOLOGY

PCB FINDINGS

WASTE CHARACTERIZATION SURVEY

SURVEY METHODOLOGY

ANALYTICAL METHODOLOGY

WASTE FINDINGS

TREATED WOOD WASTE SURVEY

SURVEY METHODOLOGY

ANALYTICAL METHODOLOGY

TREATED WOOD WASTE FINDINGS

SOLAR PANEL SURVEY

CONCLUSIONS AND RECOMMENDATIONS

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APPENDICES

Appendix A Site Maps

Appendix B Field Logs

Appendix C Asbestos Laboratory Data and Chain-of-Custody

Appendix D Lead XRF Data

Appendix E Lead Soil Laboratory Data and Chain-of-Custody

Appendix F PCB Laboratory Data and Chain-of-Custody

Appendix G Waste Characterization Data and Chain-of-Custody

Appendix H Treated Wood Waste Laboratory Data and Chain-of-Custody

Appendix I Lead Work Pre-Job Notification

Appendix J Certifications

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Hazardous Materials Pre-Renovation Survey Whiskeytown Visitor Center

Whiskeytown National Recreation Area, CA

EXECUTIVE SUMMARY

Guzi-West Inspection and Consulting (Guzi-West) contracted with Siegel and Strain

Architects (Client) to conduct a hazardous materials survey of the Whiskeytown Visitor

Center, which includes two bathrooms, a utility room, a visitor center storage room and visitor center main store lobby, located at 14412 J.F. Kennedy Memorial Road in

Whiskeytown, California. The objective of the survey was to obtain information to provide a report of the findings that consists of a descriptive listing of the hazardous or regulated materials found at the building that may impact future remodeling activities. Because proposed renovation activities are anticipated throughout the structure, the hazardous materials survey included sampling all interior and exterior homogeneous layers. Proposed renovation activities include replacement of windows, doors, insulation, electrical, HVAC system/s, interior finishes, interior furnishings and layout. The subject survey was conducted in accordance with guidelines established by the Environmental Protection Agency (EPA), Department of Housing and Urban Development (HUD), Federal and State of California

Occupational Safety and Health Organization (OSHA), and as laid out in the NPS-approved

Work Plan and Accident Prevention Plan previously prepared for this project. The survey work did not deviate from these plans. The survey/assessment was performed by Ms.

Angela Deason, a CA Certified Asbestos Consultant (CAC) and CA Department of Public

Health Lead Inspector/Assessor (DPH-I/A), on November 2, 2022. Ms. Deason was assisted by Mr. Evan Cardinaux, a trained Asbestos Building Inspector and CA Department of Public Health Lead Sampling Technician (DPH-ST). No sub-contractors were used during the project. Guzi-West trained personnel conducted sampling for asbestos-containing materials, lead-based paint, lead-contaminated soil, polychlorinated biphenyls (PCBs), treated wood waste, waste characterization profiling, and performed a visual solar panel survey in order to determine the presence or absence of antifreeze at the Whiskeytown Visitor Center.

Sampling locations are depicted on the maps provided in Appendix A; the site field log is provided in Appendix B, asbestos laboratory data is provided in Appendix C; lead laboratory data is provided in Appendix D; lead soil laboratory data is provided in Appendix E; PCB

Whiskeytown Visitor Center Page 2 laboratory data is provided in Appendix F; waste characterization data is provided in appendix G; treated wood waste laboratory data is provided in Appendix H; a Lead Work

Pre-Job Notification provided in Appendix I; and copies of applicable Guzi-West certifications are provided in Appendix J. To the extent possible, all samples were taken in inconspicuous locations, and in such a way that did not compromise the visual character of the historical features of the structure.

ASBESTOS SURVEY

SURVEY METHODOLOGY

An EPA Accredited Inspector (CAC) using required OSHA and EPA (AHERA, AHSHARA and NESHAP) methodology and standard industry best practices, collected representative bulk samples of suspect asbestos-containing building materials at the subject structure.

Following collection of the samples, the asbestos samples were double bagged and submitted to PEL Laboratory, LLC, under chain-of-custody. Each suspect asbestos-containing material (ACM) identified was bulk sampled in general accordance with sampling guidelines established by the Environmental Protection Agency and 29 CFR 1926.1101.

The following summarizes the sampling procedures utilized.

• A visual examination was conducted of both vertical and horizontal interior and exterior surfaces/component systems to determine the impact and presence of suspect hazardous material.

• Bulk asbestos samples were collected by a Guzi-West certified asbestos consultant, using procedures and techniques for bulk sample collection described in 40 CFR Part 763.86.

• All entries and penetration holes disturbed by sampling were patched.

• All potential ACM that may be impacted by the renovation activities were tested and logged. Friability determination of all suspect ACM as classified by NESHAP, e.g., Friable, Non-friable Category I or Non-friable Category II was logged. Each homogenous area was identified and noted as such in the field notes for selecting sampling locations.

• Decontamination of bulk sampling tools was used to prevent the spread of secondary contamination to subsequent bulk samples.

• Each sample was individually numbered, recorded on a Sample Log, and submitted

Whiskeytown Visitor Center Page 3 under chain-of-custody documentation to accredited laboratories.

• The locations of all samples were marked on a site map for the project, please see Appendix A.

• Measurements of all homogenous materials sampled were logged.

• Photographs of all materials sampled were collected.

• The asbestos samples were analyzed by Polarized Light Microscopy (PLM) following methods known as App. E to Sub. E of 40 CFR Part 762 and EPA/600/R‐93/116.

ANALYTICAL METHODOLOGY

Bulk samples were analyzed by PEL Laboratories (PEL), an independent laboratory located out of Ann Arbor, Michigan. PEL is an accredited National Voluntary Laboratory

Accreditation Program (NVLAP) laboratory. Analysis consisted of using the bulk samples submitted for visual observation and slide preparation(s) for microscopic examination and identification. The samples were analyzed for asbestos (Chrysotile, Amosite, Crocidolite, Anthophyllite, Actinolite, and Tremolite), fibrous non-asbestos constituents (mineral wool, cellulose, etc.), and non-fibrous constituents. Asbestos laboratory data and chain-of-custodies are provided in Appendix C.

ASBESTOS FINDINGS

Nine (9) homogenous suspect-asbestos containing materials were identified during the hazardous material survey and forty-one (41) total samples were collected. All materials sampled and analyzed came back as non-asbestos containing (i.e. asbestos was not identified at any concentration in any sample collected and submitted for analysis). The

Environmental Protection Agency (EPA) defines asbestos-containing materials (ACM) as materials containing greater than 1% asbestos analyzed by polarized light microscopy

(PLM). Cal-OSHA defines asbestos-containing construction materials (ACCM) as materials containing greater than 0.1% asbestos by PLM analysis. Even at concentrations less than

0.1%, Cal-OSHA regulations 1529 (Asbestos in Construction) still apply, as the term

“asbestos” is not defined by a specific concentration and thus means asbestos in any concentration. Therefore, identifying asbestos at any concentration is crucial for assessing risk associated with the presence of asbestos.

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The EPA’s National Emission Standard for Hazardous Air Pollutants (NESHAP) regulation requires projects disturbing over a given quantity of ACM to remove the materials containing asbestos and notify their respective local office. Specifically, the NESHAP regulation requires asbestos-containing building materials be removed prior to demolition or renovation activities if the material is considered to be a Regulated Asbestos-Containing

Material (RACM). RACM is generally defined as all friable asbestos containing material and non-friable material, which contains >1% asbestos, and that will become friable during demolition or renovation. A NESHAP notification is required in two circumstances: 1. For any demolition regardless of the presence or absence of asbestos; NESHAP regulations define a demolition as ‘removing a load-bearing structural member,’ or 2. A renovation that disturbs greater than 160 square feet or 260 linear feet of RACM. The subject project is located within Shasta County, California which falls under a ‘non-delegated’ air district and as such is regulated out the California Air Resources Board’s Sacramento office which follows the same notification amounts of 160 square feet or 260 linear feet as the Federal

Standards (certain districts have stricter notification requirements). The California

Department of Toxic Substances Control (DTSC) regulates waste disposal and classifies asbestos-containing material as hazardous waste if it is “friable” and contains one percent

(1.0%) or more asbestos as hazardous waste. A friable waste is one that can be reduced to a powder or dust under hand pressure when dry.

Table 1 below lists the homogenous suspect-asbestos containing materials sampled, location of materials, OSHA material type, friability, EPA category of work, and the asbestos content, while Table 2 below lists the quantities of suspect materials sampled and provides photographs of the materials sampled. Please see the asbestos laboratory report provided in Appendix C.

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Table 1 Asbestos Sampling Results

Homogenous Material Location

OSHA Material Type (TSI, Surfacing, or Misc.

Material)

Friability

EPA

Category

(PACM, CAT 1,

CAT 11)

Asbestos Content

Drywall / Joint Compound Throughout Misc. Material Friable Category II Non-Detect

Drywall Texture Throughout Misc. Material Friable Category II Non-Detect

Stone Mortar

Men’s Bathroom, Women’s Bathroom, Visitor Center, Storage

Room

Misc. Material

Non- Friable

Category II Non-Detect

Concrete Foundation Foundation Misc. Material Non- Friable Category II Non-Detect

Batt Insulation Throughout Misc. Material Friable Category II Non-Detect

Yellow Carpet Adhesive

Visitor Center, Storage Room Misc. Material Non-

Friable Category II Non-Detect

Brown Cove Base Visitor Center, Storage Room Misc. Material Non-

Friable Category II Non-Detect

Brown Cove Base Tan Mastic

Visitor Center, Storage Room Misc. Material Non-

Friable Category II Non-Detect

Window Caulking Exterior of Visitor Center Windows Misc. Material Friable Category II Non-Detect

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Whiskeytown Visitor Center Page 6

Table 2 Sample Description, Location, Quantity and Photograph of Suspect Asbestos-

Containing Materials

Sample Description Location Approximate

Quantity Photographs of Sampled Material

Drywall / Joint

Compound

Throughout

Structure

5,050 SF

Texture Throughout

Stone Mortar

Men’s

Bathroom, Women’s

Bathroom, Visitor Center, Storage

Room

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Whiskeytown Visitor Center Page 7

Table 2 Continued

Containing Materials Sample

Description Location

Approximate

Quantity Photographs of Sampled Material

Concrete

Foundation

Structure

Foundation

1,445 SF

Batt

Insulation

Throughout

Yellow

Carpet

Adhesive

(under carpet)

Visitor

Center, Storage Room

800 SF

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Whiskeytown Visitor Center Page 8

Table 2 Continued

Containing Materials

Sample

Description Location

Approximate

Quantity Photographs of Sampled Material

Brown Cove

Base and

Adhesive

Visitor

Center, Storage

Room

135 SF

Window

Caulking

Exterior of Visitor

Center

5,401 SF

LEAD-BASED PAINT SURVEY

An CDPH Accredited Lead Inspector/Assessor, using HUD, EPAs RRP Rule, OSHA Lead in Construction Standards and standard industry best practices, analyzed painted surfaces at the Whiskeytown Visitor Center, in order to determine lead-content. The

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Whiskeytown Visitor Center Page 9 surfaces were analyzed using a X-Ray Fluorescence (XRF) gun on-site. Each suspect lead paint sample was analyzed in general accordance with EPA, HUD, and OSHA protocols. The following summarizes the sampling procedures utilized.

• A visual examination was conducted, of both vertical and horizontal interior and suspect hazardous material.

• Painted interior and exterior surfaces were analyzed using a Viken Pb200i XRF Lead-Paint Analyzer. Portable XRF instruments expose a building component to electromagnetic radiation in the form of X-rays or gamma radiation. In response to radiation, each element, including lead, emits energy at a fixed and characteristic level. The energy released is measured by the instrument’s fluorescence detector, displayed, and logged by the inspector.

• Each surface analyzed was individually numbered and recorded on a Sample Log.

• The locations of all surfaces analyzed was marked on a site map for the project, please see Appendix A.

• Photographs of the structure and its components were collected.

A Viken Detection Pb200i Handheld XRF Lead Paint Analyzer was used for the subject project. XRF spectrometry provides a means for the rapid, non-destructive testing of paint. The principle of the method is that when exposed to high-energy radiation, lead

(like many other elements) emits X-rays at a characteristic frequency (X-ray fluorescence). These X-rays are the result of the displacement of an electron from the K or L shells of the atom (6, 16). The radiation source can be an X-ray tube or a gamma radiation source. Devices using the former can detect L shell fluorescence, while those using a gamma radiation source can detect both K and L shell fluorescence (6, 16, 22).

The intensity of the rays can be measured and correlated to the concentration of lead in the sample.

LEAD-BASED PAINT FINDINGS

Fifty-three (53) interior and exterior surfaces were analyzed for lead content. Seven (7)

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Whiskeytown Visitor Center Page 10 exterior surfaces analyzed at the visitor center contained lead-based paint;

specifically, the tan exterior siding paint is lead-based paint. In addition, lead-containing surface coatings were identified on four (4) exterior and seven (7) interior surfaces of the building. All paint was observed to be in intact (good) condition at the time of the survey.

Three federal agencies have regulations that cover renovation work in a structure. HUD’s

Lead Safe Housing Rule requires specific lead evaluation and hazard control activities for renovations in HUD-assisted target housing; the EPA’s Renovation, Repair, and Painting

(RRP) Rule requires that firms performing renovation, repair and painting activities in target housing (which is most pre-1978 housing) or in pre-1978 child-occupied facilities be certified, use trained and certified renovators, and use lead-safe work practices; and, the Federal Occupational Safety and Health Administration’s (OSHA’s) Lead in

Construction standard (29 CFR 1926.62) requires certain procedures for construction work that may expose a worker to lead. In this renovation, a X-Ray Fluorescent (XRF) gun was used to take the lead concentration in samples. The Environmental Protection

Agency (EPA), Department of Housing and Urban Development (HUD), and the California

Department of Public Health (CDPH) standards specify that any concentration of lead in paint at or above 1.0 milligram per square centimeter (mg/cm2) be considered lead-based paint and thus would be classified as ‘positive’ by XRF measurement. The California

Code of Regulations defines a lead-containing surface coating as a painted surface containing equal to or greater than 600 parts per million, ppm, lead. Any concentration of lead in paint between 0.1mg/cm and 0.9cm/cm2 would be considered a lead-containing surface coating. Utilizing XRF equipment is ideal for quickly and accurately determining lead concentrations in paint and it’s use to definitively determine paint as containing levels of lead at or above lead-based paint criteria is widely accepted. Measurements of lead in paint below that of lead-based paint can still be regulated however and numerous studies have been completed in an attempt to quantify these measurements. The

Chevron Research and Technology Company conducted a detailed study in 1995-1996 comparing XRF measurements versus analysis by atomic absorption spectrometry (AAS)

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Whiskeytown Visitor Center Page 11 in an effort to determine how XRF measurements below 1.0 mg/cm2 compare to measurements by atomic absorption spectrometry. Their findings are often referred to in the lead paint industry and Guzi-West utilizes their findings to summarize whether a paint is definitively considered a lead-based paint (paint with equal to or greater than 1.0 milligram per square centimeter (mg/cm2), would likely be considered a lead-containing surface coating (paint with concentrations of lead in paint between 0.1 mg/cm2 – 0.9 mg/cm2), or paint which likely contains low levels of lead or no lead at any concentration

(paint with concentrations of lead less than 0.1 mg/cm2). The table below presents the information in tabular form for ease of reference.

XRF Measurement AAS Comparable Measurement Paint Classification =/> 1.0 mg/cm2 =/> 5,000 ppm Lead-Based Paint

0.1 mg/cm2 – 0.9 mg/cm2

600 ppm – 4,999 ppm Lead-Containing Surface Coating (assumed)

< 0.1 mg/cm2 <600 ppm Likely paint with very low levels of lead or no lead

A pre-project notification form must be submitted to Cal-OSHA at least 24 hours prior to any disturbance if more than 100 square feet of lead-based paint may be disturbed during the subject renovation; please see the Cal-OSHA Lead Work Pre- Job Notification Form

& Summary of Cal-OSHA’s Lead in Construction Standard provided in Appendix H.

Prospective contractors should have training in accordance with the requirements of Title

8, California Code of Regulations, Section 1532.1 and ensure proper worker protection is utilized during any disturbance of paint containing lead. Table 3 below identifies the sample location, lead concentration, paint classification, and paint condition of each sample analyzed that contains lead; please see the lead laboratory report provided in Appendix

D.

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Whiskeytown Visitor Center Page 12

Table 3 Lead-Based Paint & Lead-Containing Surface Coatings

Location Lead Concentration

LCSC – lead-containing surface coatings LBP – lead-based paint

Paint Condition

Interior Brown Window, Men’s Bathroom 0.1 mg/cm2 LCSC Intact

Interior Brown 1”x1” Ceramic Tile, Men’s Bathroom Floor 0.1 mg/cm2 LCSC Intact

Interior Black Door Frame, Women’s Bathroom 0.1 mg/cm2 LCSC Intact

Interior Brown Window, Women’s Bathroom 0.2 mg/cm2 LCSC Intact

Interior Tan Stall Door, Women’s Bathroom 0.1 mg/cm2 LCSC Intact

Interior White Wall, Visitor Center 0.1 mg/cm2 LCSC Intact Interior Brown Door, Visitor Center 0.1 mg/cm2 LCSC Intact Exterior Brown Trim, East Wall 0.1 mg/cm2 LCSC Intact Exterior Tan Siding, North Wall 2.5 mg/cm2 LBP Intact Exterior Tan Siding, North Wall 3.7 mg/cm2 LBP Intact Exterior Tan Siding, North Wal 3.3 mg/cm2 LBP Intact Exterior Tan Siding, West Wall 5.1 mg/cm2 LBP Intact Exterior Tan Siding, West Wall 5.9 mg/cm2 LBP Intact Exterior Brown Door Frame, West Wall 0.1 mg/cm2 LCSC Intact

Exterior Tan Siding, West Wall 6.1 mg/cm2 LBP Intact Exterior Tan Siding, South Wall of Visitor Center 6.7 mg/cm2 LBP Intact

Exterior Green Gutter, West Roof 0.1 mg/cm2 LCSC Intact Exterior Brown Overhang Support Post 0.1 mg/cm2 LCSC Intact

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Whiskeytown Visitor Center Page 13

LEAD-IN-SOIL SURVEY

An CDPH Accredited Lead Inspector/Assessor, using HUD, EPAs RRP Rule, OSHA Lead

In Construction Standards and standard industry best practices, collected composite soil samples along all four sides of the visitor center. Each suspect sample was collected in general accordance with EPA, HUD, and OSHA protocols. The following summarizes the sampling procedures utilized.

• A visual examination was conducted of exterior soil patches under the dripline, in order to determine the impact and presence of suspect hazardous material.

• Soil samples were collected utilizing gloves, a plastic hand tool, and along pre-determined rows.

• One sample was collected from each side of the building (North, South, East, West), for a total of four composite samples. Each composite sample was made up of a pre-determined number of soil samples collected at 3 foot intervals of exposed soil.

• Each sample collected was recorded on a Sample Log and site map; please see Appendix A

• Photographs of the exposed soil patches are provided in Table 3.

• The soil samples were then shipped under chain-of-custody documentation to McCampbell Analytical, Inc., a state-certified laboratory, for analysis of lead by EPA Method 6010B.

Soil samples were shipped under chain-of-custody documentation to McCampbell

Analytical, Inc., a state-certified laboratory, for analysis of lead by EPA Method 6010b.

The method measures ions produced by a radio-frequency inductively coupled plasma.

Analyte species originating in a liquid are nebulized and the resulting aerosol is transported by argon gas into the plasma torch. The ions produced by high temperatures are entrained in the plasma gas and introduced, by means of an interface, into a mass spectrometer. The ions produced in the plasma are sorted according to their mass-to-charge ratios and quantified with a channel electron multiplier.

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Whiskeytown Visitor Center Page 14

LEAD-IN-SOIL FINDINGS

Due to lead-based paint being identified on the exterior of the structure, one composite soil sample was collected from each side of the structure, for a total of four (4) samples collected and submitted for analysis. The most stringent lead in soil criteria was developed by the State of California-EPA’s Office of Environmental Health Hazard

Assessment (OEHHA); OEHHA evaluated potential exposures to estimate lead concentrations in soil that would lead to an incremental increase in blood lead. OEHHA subsequently issued revised California Human Health Screening Levels (CHHSLs) for lead and lead compounds where concentrations of lead in soil up to 80 mg/km or ppm are considered appropriate for residential property and concentrations of lead in soil up to 320 mg/km or ppm soil are considered appropriate for commercial/industrial property.

These levels are notably lower than the HUD definitions for lead-contaminated soil - bare soil that contains an amount of lead equal to, or in excess of, four hundred parts per million (400 ppm) in children’s play areas and one thousand parts per million (1,000 ppm) in all other areas. All four (4) samples submitted had lead concentrations below both the residential and commercial/industrial property California Human Health Screening Levels (CHHSLs) for lead. That said, we recommend contractors who have employees who could be exposed to lead at any concentration have training in accordance with the requirements of Title 8, California Code of Regulations, Section

1532.1 and conduct periodic monitoring to ensure employees are not exposed above the action level or permissible exposure level.Cal-OSHA requires worker protection for lead exposure when lead is identified at any concentration, regardless of whether the amount of lead exceeds lead-based paint criteria, lead-containing surface coatings (equal to or greater than 600 ppm lead), lead in soil, or lead in dust. Effectively, Cal-OSHA takes the stance that employers shall either assume employees are being exposed above the permissible exposure limit (PEL) if any lead is present and protect their employees accordingly or provide evidence through previous exposure monitoring that utilization of specific engineering controls and personal protective equipment results in exposures below the PEL for projects with similar work scopes. Table 4 below lists the sample

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Whiskeytown Visitor Center Page 15 locations, lead-in-soil concentrations and photographs of the soil patch where soil samples were collected. A copy of the laboratory report is provided in Appendix E.

Table 4 Lead-In-Soil Concentrations

Sample Location Lead

Photograph of Sampling Location

West Exterior 16 mg/kg

South Exterior 27 mg/kg

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Whiskeytown Visitor Center Page 16

Table 4 Continued Lead Soil Concentrations

Sampling Location

Lead

Photograph of Sampling Location

North Exterior 19 mg/kg

East Exterior 0 mg/kg

PCB SURVEY

An EPA Accredited Inspector (CAC) using required OSHA and EPA (AHERA, AHSHARA and NESHAPS) methodology, and standard industry best practices, collected representative bulk samples of PCB-containing building materials. Following collection of the samples, the PCB samples were double bagged and shipped to McCampbell

Analytical, Inc., under chain-of- custody. Each suspect PCB-containing material

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Whiskeytown Visitor Center Page 17 identified, was bulk sampled in general accordance with sampling guidelines established by Environmental Protection Agency 40 CFR 761 parts M, O, P, and R. The following summarizes the sampling procedures utilized.

suspect hazardous material.

• Bulk PCB samples were collected, using procedures and techniques for bulk sample collection described in 40 CFR Part 761.

• All entries and penetration holes disturbed by sampling were patched.

• Decontamination of bulk sampling tools was used to prevent the spread of secondary contamination to subsequent bulk samples.

• Each sample was individually numbered, recorded on a Sample Log, and submitted under chain-of-custody documentation to accredited laboratories.

• The locations of all samples were marked on a site map for the project, please see Appendix A.

• Photographs of all materials sampled were collected.

• The PCB samples were extracted using Method SW 3550B, and analyzed by Method SW8082.

Bulk samples were analyzed by McCampbell Analytical, Inc., an independent laboratory located in the San Francisco Bay Area. McCampbell Analytical is an accredited National

Environmental Laboratory Accreditation Program (NELAP) laboratory.

Bulk samples were analyzed by utilizing the Method 8082A, polychlorinated biphenyls by gas chromatography. Method 8082 is used to determine the concentrations of polychlorinated biphenyls (PCBs) as Aroclors or as individual PCB congeners in extracts from solid and aqueous matrices. Open tubular, capillary columns are employed with electron capture detectors (ECD) or electrolytic conductivity detectors (ELCD). When compared to packed columns, these fused-silica, open-tubular columns offer improved

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Whiskeytown Visitor Center Page 18 resolution, better selectivity, increased sensitivity, and faster analysis. The target compounds may be determined by either a single- or dual-column analysis system.

PCB FINDINGS

The California Department of Toxic Substances Control (DTSC) has classified PCBs as a hazardous waste when the concentrations are equal to or greater than 5 mg/l in liquids or when the total concentrations are equal to or greater than 50 mg/kg in nonliquids (Title

22, CCR, 66261.24). If the PCB waste is greater than 50 mg/l then it is also to be managed under the Resource Conservation and Recovery Act (RCRA) and Toxic

Substances Control Act (TSCA) requirements. Some generators and all transporters, storage facilities, and disposers of PCB wastes must notify the EPA that they are engaging in such activity and obtain an identification number from the EPA. Current PCB regulations, published pursuant to the TSCA statute, can be found in Title 40 of the Code of Federal Regulations (CFR) in Part 761.

Seven (7) bulk samples were collected at the Whiskeytown Visitor Center, in order to determine PCB content. The samples included drywall/joint compound/paint, concrete, carpet and adhesive, brown cove base, brown cove base mastic, and window caulking/paint. Out of the seven samples collected from the subject structure, none contain PCBs above regulatory limits; please see the laboratory report provided in Appendix F.

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Whiskeytown Visitor Center Page 19

Polychlorinated Biphenyls (PCBs) Concentrations

Material Location Sampled PCBs Total Concentration*

Material Condition

Drywall/Joint Compound/Paint Men’s Restroom Non-Detect Intact

Drywall/Joint Compound/Paint

Women’s Restroom Non-Detect Intact

Concrete Utility Closet Non-Detect Intact

Carpet/Adhesive Visitor Center Store Non-Detect Intact

Brown Cove Base Visitor Center Store Non-Detect Intact

Brown Cove Base Tan Adhesive Visitor Center Store Non-Detect Intact

Window Caulking/Paint Visitor Center Exterior West

Window Non-Detect Intact

*PCBs total concentration includes analysis of Aroclor1016, Aroclor1221, Aroclor1232, Aroclor1242, Aroclor1248, Aroclor1254, Aroclor1260.

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Whiskeytown Visitor Center Page 20

WASTE CHARACTERIZATION SURVEY

An EPA Accredited Inspector using required OSHA and EPA (RCRA) methodology, and standard industry best practices, collected one single composite sample of the waste stream. Following collection of the sample, the waste sample was double bagged and sent to McCampbell Analytical, Inc. under chain-of- custody, a state-certified laboratory, for analysis of the Title 22 Metals by EPA Method 6020 with the exception of mercury, which was analyzed by EPA Method 7471A, polychlorinated biphenyls (PCBs) by EPA Method

8082, percent moisture by Method SM 2540G, and pH by EPA Method 9045C. The waste stream was sampled in general accordance with sampling guidelines established by the

Environmental Protection Agency’s recommended procedures for sampling solid waste under the Resource Conservation and Recovery Act (RCRA). The following summarizes the sampling procedures utilized.

suspect hazardous material.

• A single composite sample of the waste stream was collected by obtaining a cross section of all building materials on site. Specifically, the sample was collected utilizing gloves, a plastic hand tool, and compositing the sample into a single 1-gallon Ziploc bag.

• All entries and penetration holes disturbed by sampling were patched.

• Decontamination of bulk sampling tools was used to prevent the spread of secondary contamination to subsequent bulk samples.

• The sample was individually numbered, recorded on a Sample Log, and submitted under chain-of-custody documentation to an accredited laboratory.

• The sample was submitted for analysis of the Title 22 Metals by EPA Method 6020 with the exception of mercury which was analyzed by EPA Method 7471A, polychlorinated biphenyls (PCBs) by EPA Method 8082, percent moisture by Method SM 2540G, and pH by EPA Method 9045C.

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Whiskeytown Visitor Center Page 21

One bulk sample was analyzed by McCampbell Analytical, Inc., an independent laboratory located in the San Francisco Bay Area. McCampbell Analytical is an accredited

National Environmental Laboratory Accreditation Program (NELAP) laboratory. The bulk sample was submitted for analysis of the Title 22 Metals by EPA Method 6020 with the exception of mercury which was analyzed by EPA Method 7471A, polychlorinated biphenyls (PCBs) by EPA Method 8082, percent moisture by Method SM 2540G, and pH by EPA Method 9045C.

WASTE CHARACTERIZATION FINDINGS

Following receipt of the sample results, the respective findings were compared against the regulatory thresholds for hazardous wastes established under Title 22 of the California

Code of Regulations as well as for requirements and thresholds specifically required for disposal under Shasta County’s West Central Landfill Waste Acceptance Criteria Report

(August 2013). The Waste Acceptance Criteria Report provides hazardous waste limits specified under Title 22 of the California Code of Regulations for concentrations expressed in Total Threshold Limit Concentrations (TTLC), TTLC results which would trigger further analysis by soluble analytical laboratory methods, as well as Designated

Waste Criteria with more stringent TTLC limits suggested by the State Water Resources

Control Board. The table on the following page identifies each of the respective limits as well as the results for the subject project. As evidenced by the Table 6 below and laboratory data in Appendix G, all CAM 17 metals, PCBs, percent moisture, and pH are below their respective thresholds TTLC, STLC, and TCLP thresholds.

Therefore, excluding treated wood waste and solar panels (discussed further in the next Sections) construction waste from the subject project should be classified as general construction debris, as no asbestos, PCBs, CAM 17 metals, pH or loose/flakey lead-based paint are present which would require special waste handling. Should lead-based paint abatement become necessary for a given renovation area then the lead-based paint chips must be disposed of as hazardous waste. Field observations indicated all paint was well adhered to its respective

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Whiskeytown Visitor Center Page 22 substrate/s and thus we do not anticipate special waste handling being required due to the presence of lead-based paint.

Table 6 Debris Waste Characterization

ANALYTE

HAZARDOUS WASTE

DESIGNATED

WASTE

PROJECT SAMPLE

TTLC (mg/kg) STLC (mg/l) Limit3

TCLP (mg/l) Limit6

TTLC (mg/kg) Limit7

TTLC (mg/kg)

Limit3 STLC Req'd4 TCLP Req'd5

Antimony 500 150 - 15 - 310 ND Arsenic 500 50 100 5 5 15 2.8

Barium (excluding barite) 10,000 1000 2000 100 100 2600 76 Beryllium 75 7.5 - 0.75 - 22.5 9 ND Cadmium 100 10 20 1 1 39 ND Chromium 2,500 50 - 5 - 750 17

Cobalt 8,000 800 - 80 - 94 3.7 Copper 2,500 250 - 25 - 750 14 Lead 1,000 50 100 5 5 750 5.5

Mercury 20 2 4 0.2 0.2 6 0.34 Molybdenum 3,500 3500 - 350 - 1050 ND

Nickel 2,000 200 - 20 - 260 13 Selenium 100 10 20 1 1 30 ND

Silver 500 50 100 5 5 150 ND Thallium 700 70 - 7 - 62 ND Vanadium 2,400 240 - 24 - 770 31

Zinc 5,000 2500 - 250 - 1500 59

HAZARDOUS WASTE DESIGNATED

WASTE

PROJECT WASTE SAMPLE

TTLC (mg/kg) STLC (ug/l) Limit

TTLC (mg/kg) Limit13

TTLC (mg/kg) Limit11 STLC Rec’d

PCB 50 0.1 10 >/= Reporting Limit

ND

ANALYTE LIMIT 14, 15 (%) PROJECT WASTE SAMPLE

Moisture Content 50 1.04

ANALYTE LIMIT/S PROJECT WASTE SAMPLE

pH < 2.0 or ≥ 12.5 6.02

Disclaimer:

1. Per T22 CCR WET Method

2. Per T40 CFR TCLP Method

3. Exceedance of listed values classifies the waste as T22 hazardous waste.

4. Exceedance of listed value requires STLC analysis

5. Exceedance of listed value requires TCLP analysis

6. Exceedance of listed values classifies the waste as T40 hazardous waste.

7. Exceedance of the listed values requires a designated waste determination by the CRWQCB.

8. San Francisco Bay Region CRWQCB ESL (deep soil w/ groundwater as a potential source of drinking water)

9. San Francisco Bay Region CRWQCB ESL exceeds hazardous waste screening limit, value based on 30% of hazardous waste TTLC screening limit

Whiskeytown Visitor Center Page 24

TREATED WOOD WASTE SURVEY

According to the California Department of Toxic Substances Control (DTSC) Treated

Wood Waste (TWW) is wood that has gone through a treatment process with chemical preservatives to protect it against pests and environmental conditions. TWW has the potential to be a hazardous waste if it contains elevated levels of one or more of the following constituents: arsenic, chromium, copper, pentachlorophenol, and/or creosote.

An EPA Accredited Inspector using required OSHA and DTSC methodology, and standard industry best practices, collected one single bulk composite sample of the structures wood waste stream. Following collection of the sample, the waste sample was double bagged and sent to California Laboratory Services, under chain-of-custody, a state-certified laboratory, for analysis of arsenic, chromium, copper, pentachlorophenol, and creosote. The following summarizes the sampling procedures utilized.

suspect hazardous material.

• Bulk wood samples were collected throughout the interior and exterior of the structure in order to gather one composite bulk wood sample. Specifically, the samples were collected utilizing gloves, a chisel, and compositing the samples into a single 1-gallon Ziploc bag.

• All entries and penetration holes disturbed by sampling were patched.

• Decontamination of bulk sampling tools was used to prevent the spread of secondary contamination to subsequent bulk samples.

• The sample was individually numbered, recorded on a Sample Log, and submitted under chain-of-custody documentation to an accredited laboratory.

Again, one bulk sample was submitted and analyzed by California Laboratory Services., a privately held, full-service environmental chemistry testing laboratory, certified by the

Whiskeytown Visitor Center Page 25

Department of Health Services. The waste sample was submitted for analysis of Arsenic, Copper, and Chromium by EPA Method 6020, and Pentachlorophenol and Creosote (2-

Methylphenol and 3 & 4-Methylphenol) by EPA Method 8270C. It should be noted three types (or isomers) of cresols exist: ortho-cresol, meta-cresol, and para-cresol; abbreviated as o-cresol (2-Methylphenol), m-cresol (3-Methylphenol), and p-cresol (4-Methylphenol).

Following receipt of the sample results, the subject structure’s wood waste stream concentrations was compared against the regulatory thresholds for hazardous wastes established under Title 22 of the California Code of Regulations as well as for requirements and thresholds specifically required for disposal at West Central Landfill, who publishes specific limits for potential contaminants as well as thresholds which require further analyses, such as solubility testing, to be performed.

TREATED WOOD WASTE FINDINGS

Following receipt of the sample results, the respective metal’s (Arsenic, Chromium and

Copper) Total Threshold Limit Concentrations (TTLC) concentrations were compared against the regulatory thresholds for hazardous wastes established under Title 22 of the

California Code of Regulations. Meanwhile, the respective semi-volatiles

(Pentachlorophenol and Creosote) were also compared against the regulatory thresholds for hazardous wastes established under Title 22 of the California Code of Regulations.

Table 7 provided below, and the laboratory results provided in Appendix G, depicts the metals and semi-volatile concentrations/values for the composite wood waste samples and is followed by the accompanying laboratory reports. As evidenced by the table, all total metals and semi-volatile concentrations are well below Title 22 limits and therefore the waste stream from the subject projects is below hazardous waste screening criteria.

That said, the wood from the structure appears to fall under the DTSC definition of a treated wood waste and the subject project will result in the incidental generation of TWW;

therefore, we recommend TWW from the projects be segregated from the rest of the renovation debris and disposed of as TWW at a landfill approved to accept TWW (Waste

Management’s Anderson Landfill appears to be the closest such disposal facility. Upon acceptance at these certain landfills, the TWW, at that point, becomes non- hazardous

Whiskeytown Visitor Center Page 26 waste pursuant to Health and Safety Code section 25230.16. According to DTSC, businesses that “incidentally” generate TWW can generally comply with handling and disposal requirements by abiding by the following conditions:

1. Do not burn the TWW.

2. Do not remove or destroy any marking identifying the wood as treated wood.

3. Keeping TWW segregated from other materials.

4. Labeling all TWW bundle/shipments with the following information:

1. TREATED WOOD WASTE – Do not burn or scavenge.

2. TWW Handler Name: ; Address: : Accumulation Date:

5. Storing no more than 1,000 pounds of TWW for no longer than 30 days. Incidental generators who store TWW for more than 30 days are subject to the additional requirements for businesses that are routine generators of TWW.

6. Transporting TWW to an authorized TWW facility. A complete list of landfills approved to accept TWW is available at the following link:

https://www.waterboards.ca.gov/water_issues/programs/land_disposal/treated_ w ood_waste.html.

7. Identifying TWW to TWW facility personnel.

8. Train employees involved in TWW handling and keep the training records for three years. The training shall include applicable requirements of Cal/OSHA and regulations relating to hazardous waste, methods for identifying and segregating

TWW, safe handling practices, requirements of AMS; and proper disposal methods. (HSC 25230.12).

https://www.waterboards.ca.gov/water_issues/programs/land_disposal/treated_wood_waste.html

Table 7 Treated Wood Waste Debris Waste Characterization

PROJECT SAMPLE 401

TTLC (mg/kg) Thresholds STLC (mg/l)

Limit3 TCLP (mg/l)

Limit6 TTLC (mg/kg)

Limit3 STLC Req'd4 TCLP Req'd5

Arsenic 500 50 100 1.5 5 ND Chromium 2,500 50 - 19 - 2.3

Copper 2,500 250 - 27 - 5.6 Solubility analyses (STLC and TCLP) were not required as each project sample concentration via TTLC analysis is below the respective thresholds triggering solubility analyses.

TCLP (mg/L) STLC (ug/l) Limit

TTLC (ug/kg) Limit

PROJECT SAMPLE 401

Limit STLC Rec’d Pentachlorophenol

100.0

0.1

1.7

17,000 ND

(<8,300 ug/kg)

Creosote (2-Methylphenol)

200.0

Not Established

ND

(<3,300 ug/kg)

Creosote (3 & 4-Methylphenol)

200.0

ND

(<3,300 ug/kg)

Solubility analyses (STLC and TCLP) were not required as each project sample concentration via TTLC analysis is below the respective thresholds triggering solubility analyses.

* Footnotes on following page

1. Per T22 CCR WET Method

2. Per T40 CFR TCLP Method

3. Exceedance of listed values classifies the waste as T22 hazardous waste.

4. Exceedance of listed value requires STLC analysis

5. Exceedance of listed value requires TCLP analysis

6. Exceedance of listed values classifies the waste as T40 hazardous waste.

7. Exceedance of the listed values requires a designated waste determination by the CRWQCB.

8. San Francisco Bay Region CRWQCB ESL (deep soil w/ groundwater as a potential source of drinking water)

9. San Francisco Bay Region CRWQCB ESL exceeds hazardous waste screening limit, value based on 30% of hazardous waste TTLC screening limit

Whiskeytown Visitor Center Page 29

SOLAR PANEL SURVEY

Standing and roof-mounted Solarex solar panels are present at the Whiskeytown Visitor

Center. As of November 2, 2022, the standing 3-pane solar panel on the north side of the visitor center was not in use, but the roof mounted Solarex solar panels were in use. These solar panels are defined as PV modules; therefore, they are subject to all hazardous waste regulations. Solar panels contain toxic heavy metals that require RCRA hazardous waste management when it comes time to recycle or dispose of them. Under SB 489, the

California Department of Toxic Substances Control (DTSC) classifies PV module solar panels that have not undergone the verification process, as universal waste, which is a type of hazardous waste. A PV module is defined as a device consisting of, or containing, one or more electrically connected photovoltaic cells that are designed to convert solar radiation into electrical energy. PV module is defined in California Code of Regulations, title 22, division 4.5, chapter 23, article 1, section 66273.9 , and includes any ancillary components that cannot be manually separated without breaking the photovoltaic module glass such as, but not limited to, metal frames used to support the PV module, connectors, junction boxes, batteries, inverters, wires, and cables that are connected to the PV module. The ancillary components part of the visitor center solar panel PV system, including the junction box, battery, inverter, and cables, are not considered to be a universal waste PV modules, and are considered residuals that must be managed under respective laws and regulations applicable to them.

Once a universal waste handler decides to discard universal waste PV modules, the wastes become subject to all hazardous waste regulations. The handler is required to perform a hazardous waste determination on the waste and manage the waste based on that determination. If the waste is hazardous, it must be disposed of as hazardous waste using full hazardous waste standards. Notification and annual reporting are two different reporting requirements under universal waste regulations. The notification is a one-time event for handlers of PV modules that intend to accept or anticipate accepting PV module waste from generators or other universal waste handlers. The notification is required for each location a universal waste handler accepts, accumulates, or treats PV modules as universal waste. The notification must be submitted to DTSC in writing 30

Whiskeytown Visitor Center Page 30 days prior to accepting universal waste PV modules. This notification only occurs one time. An annual report is required to be submitted every year to DTSC for universal waste handlers that accept more than 100 kilograms (220 pounds) or generate more than 5,000 kilograms (11,000 pounds) of universal waste PV modules in a calendar year. An annual report must be submitted to DTSC, in writing, by February 1 of the following year for the prior calendar year that you handled universal waste PV modules.

CONCLUSIONS AND RECOMMENDATIONS

As explained in detail above, no asbestos or PCB-containing building materials were identified in the survey. Furthermore, the project does not involve a demolition; therefore, the subject project does not require a NESHAP notification to perform renovation activities.

Lead-based paint was identified on the exterior of the visitor center, and lead-containing surface coatings were identified on the interior of the building; therefore, Guzi-West recommends all exterior painted surfaces be treated as lead-based paint, and all interior painted surfaces be treated as lead-containing surface coatings. Although, small concentrations of lead were found in 3 exterior soil samples, all soil samples had lead concentrations below the residential and commercial/industrial California Human Health

Screening Levels (CHHSLs). Regardless of lead content, prospective contractors should have training in accordance with the requirements of Title 8, California when dealing with any concentration of lead. A pre-project notification should be submitted to Cal-OSHA if greater than 100 square feet of lead-based paint will be disturbed during proposed renovation activities; please see the Cal-OSHA Lead Work Pre-Job Notification Form provided in

Appendix I.

The composite wood sample submitted for analysis detected low levels of Chromium and

Copper; however, all total metals and semi-volatile concentrations are well below Title 22 limits; therefore, the wood waste stream from the subject project is below hazardous waste screening criteria. That said, the wood from the structure appears to fall under the DTSC definition of a treated wood waste and the subject project will result in the incidental generation of TWW; therefore, we recommend TWW from the projects be segregated from the rest of the renovation debris and disposed of as TWW at a landfill approved to accept

Whiskeytown Visitor Center Page 31

TWW (Waste Management’s Anderson Landfill appears to be the closest such disposal facility). In regards to the bulk waste stream as a whole, all CAM 17 metals, PCBs, percent moisture, and pH are well below their respective thresholds TTLC, STLC, and TCLP thresholds.

Lastly, the solar panels are defined as PV modules; therefore, they are subject to all hazardous waste regulations. Components that are connected to PV modules and can be manually separated from a PV module without breaking the PV module glass are considered to be ancillary components. The ancillary components part of Whiskeytown visitor center solar panels PV system, including the junction box, battery, inverter, and cables, are not considered to be a universal waste PV module and are considered residuals that must be managed under respective laws and regulations applicable to them. Under universal waste regulations, the generator of the waste PV modules has the option to manage the waste as universal waste without making a hazardous waste determination.

The generator may take the waste to a universal waste handler that accepts the waste as universal waste.

Since no asbestos-containing materials were identified, and all lead-based paint is in intact condition, we do not anticipate abatement being necessary; therefore, a Class C Cost

Estimate is not required at this time. All regulations presented herein are complicated and subject to change. The intent of the above information is to advise you of some of the regulations that may affect you, but is not intended to be an all-encompassing discussion of all regulations pertinent. The sole purpose of this investigation and of this report is to assess the site with respect to asbestos-containing materials, painted surfaces containing regulated levels of lead, suspect lead-containing soil, suspect materials containing PCB’s, suspect treated wood waste, waste characterization, and solar panels. Guzi-West is not responsible for locating these materials in inaccessible areas such as behind walls, above hard ceilings, beneath flooring, or underground. This report has been prepared on behalf of and for the exclusive use of Siegel and Strain Architects and Whiskeytown National

Recreation…