Attachment_02_Report_of_Asbestos_Sampling_0001.pdf

REPORT OF ASBESTOS SAMPLING

1. General

1.1. Requestor of investigation: NPS, Golden Gate National Recreation Area, Tony DiStefano

1.2. Job number: C00575-01

1.3. Date and time of investigation: 11/30/23, 1:00pm

1.4. Date of report: 12/12/23

1.5. Previous Reports: HTA has performed several surveys and written several reports for this property, see HTA 2022 -Site Specifications Compliance Plan for Hazardous Materials for list.

1.6. Location of building: Fort Mason, Building 201 – exterior elevator door frame, San Francisco

1.7. HTA Personnel: Tolinda Thompson, CAC #10-4637

2. Investigation Description

2.1. Focus of Concern (Description of Work Requested/Authorized)

HTA was requested by Tony DiStefano to inspect and sample the exterior frame for potential asbestos. HTA was asked to check if the frame contained asbestos such as fireproofing and in the paint.

2.2. Structure status at time of investigation: The building was partially furnished and partially occupied at the time the work was performed. The frame in question was the exterior access door of the elevator.

2.3. Photos:

H T A

SCIENCE & ENGINEERING, INC.

Licensed by California State Board for Professional Engineers

CSLB #813806

PO Box 1930 Fair Oaks, CA 95628-5838

916-965-4235 fax: 916-965-1167

W W W . H T A E N G I N E E R I N G . C O M

– 2 – December 13, 2023

3. Asbestos Results There was a hole in the frame that we were able to use to determine that the frame was hollow. Bulk paint samples were collected from the frame. These samples demonstrated that there was no asbestos in the paint.

3.1. Definitions

Asbestos Containing Material (ACM): Any manufactured material which contains greater than one percent asbestos.

Category I Non-friable Asbestos Containing Material (ACM): Asbestos containing packing, gaskets, resilient floor covering, and asphalt roofing products containing more than I percent asbestos as determined using the method specified in Appendix A, subpart F, 40 CFR part 763, section 1, Polarized Light Microscopy.

Category II Non-friable ACM: Any material, excluding Category I non-friable ACM, containing more than 1 percent asbestos as determined using the methods specified in Appendix A, subpart F, 40 CFR part 763, section 1, Polarized Light Microscopy that, when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure.

Class II Asbestos Removal: Class II Asbestos Work means activities involving the removal of ACM which is not thermal system insulation or surfacing material. 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 Removal: Class III Asbestos Work means activities involving the repair and maintenance operations, where ACM, including thermal system insulation and surfacing material, is likely to be disturbed.

NESHAP: The National Emissions Standards for Hazardous Air Pollutants (NESHAPS) are emissions standards set by the United States EPA for an air pollutant not covered by NAAQS that may cause an increase in fatalities or in serious, irreversible, or incapacitating illness. The standards for a particular source category require the maximum degree of emission reduction that the EPA determines to be achievable, which is known as the Maximum Achievable Control Technology (MACT). These standards are authorized by Section 112 of the Clean Air Act and the regulations are published in 40 CFR Parts 61 and 63.

PCM: Phase Contrast Microscopy as it relates to clearance air, personnel exposure assessment and ambient air monitoring. This procedure must follow NIOSH Method 7400, Asbestos Fibers by PCM PLM: Polarized Light Microscopy used for bulk sample analysis with dispersion staining for the determination and quantifying of Asbestos in Bulk Samples building materials.

Regulated Asbestos Containing Material (RACM): (a) Friable asbestos material, (b) Category I non-friable ACM that has become friable, (c) Category I non-friable ACM that will be or has been subjected to sanding, grinding, cutting, or abrading, or (d) 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 regulated by 40 CFR 6 1.

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TEM: Transmission Electron Microscopy as defined for Asbestos clearance air monitoring within AHERA. This procedure must follow the NIOSH Method 7402, Asbestos Fibers by TEM

3.2. Asbestos and its uses

Asbestos is a term that refers to a group of naturally occurring fibrous minerals.

Because of their resistance to decay and their remarkable insulating properties, asbestos fibers have been incorporated into thousands of products and materials.

Collectively these products are frequently referred to as asbestos-containing materials (ACM). Many types of ACM have been used in the construction of buildings and homes. ACM types are generally put into one of three classifications, they are:

1. Surfacing materials Surfacing materials are those products, which have been sprayed or troweled onto ceilings, walls, and other structural elements. (e.g., fireproofing, thermal insulation, or decoration). Because of the type of mixture used in the construction industry, these materials are commonly friable, that is they are easily crushed or reduced to powder form with hand pressure.

2. Thermal systems insulation (TSI) The insulation applied to mechanical systems, hot water pipes and heating ducts often contains asbestos. Hot water pipes and heating systems are covered with asbestos insulation primarily to prevent heat loss and to protect other nearby surfaces from the hot pipes. Much of this asbestos insulation was manufactured from 1920 to 1972, and it was used in construction until 1978.

3. Miscellaneous Miscellaneous ACM materials include all asbestos products, which cannot be classified as either surfacing material or TSI. These materials are usually non-friable and generally do not release asbestos fibers into the air unless damaged.

Products such as floor tile, mastic, roofing material and concrete asbestos products are examples of miscellaneous ACM.

3.3. Current Asbestos Regulations

The following is a summary of select major state and federal asbestos regulations.

These summaries are not intended to be a comprehensive discussion of the specific regulations. In addition, this summary is not an all-inclusive overview of the asbestos regulatory universe.

Division of Occupational Safety and Health (Cal-OSHA) – Title

8 CCR § 1529

On July 2, 1996, Cal-OSHA implemented revised general industry and construction asbestos standards, which apply to all occupational exposure to asbestos. The new Cal-OSHA construction standard requires owners of buildings built prior to 1981 to presume that a variety of building materials contain asbestos unless they are sampled and proved to not contain asbestos. Employers whose employees work in these same buildings face the same responsibility to either test materials or treat them as ACM.

The standard describes four classes of asbestos-related work: I) removal of asbestos thermal systems insulation and surfacing materials, II) removal of asbestos material

– 4 – December 13, 2023 which are not thermal systems insulation or surfacing materials, III) repair and maintenance operations where small amounts of asbestos or presumed asbestos (PACM) is likely to be disturbed, and IV) maintenance and custodial 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. For each class, OSHA specifies the type of training, work practices, air sampling, and personal protection required of the employer and worker. This new regulation is a jobs-based standard. Specific notifications and work practices are required if asbestos will be disturbed.

EPA's NESHAP Regulation – 40 CFR Part 61, Subpart M NESHAP requires building owners to inspect a building for asbestos prior to renovation or demolition. The EPA must be notified in advance of all demolition (whether there is asbestos present or not) and if more than 160 square feet, 260 linear feet, or 35 cubic feet of Regulated Asbestos Containing Materials (RACM) are going to be disturbed during renovation. RACM must be removed before any demolition or renovation work disturbs it. Specific work practices must be followed during the removal of RACM. RACM must be adequately wet when disturbed and must remain wet until placed in leak-proof containers. No visible emissions are allowed during collection, packaging, transportation, or disposal of RACM. Records must be kept regarding the transportation and disposal of RACM.

In many areas the federal NESHAP regulation is enforced by the local air quality management district (AQMD). In many cases, EPA has "delegated" NESHAP enforcement to these local agencies. Each AQMD has developed an enforcement regulation based on the NESHAP regulation, and in many instances these local regulations are more stringent than the Federal EPA NESHAP regulation.

4. Exclusions and Report Limitations

4.1. This report has been prepared by HTA for the exclusive use of HTA and its client, and not for use by any other party. The sampling results discussed in this report may not be appropriate for uses beyond its intended purpose and stated scope. Any use by a third party of any of the information contained in this report shall be at their own risk and shall constitute a release and an agreement to defend and indemnify HTA from any and all liability in connection therewith whether arising out of HTA's negligence or otherwise.

4.2. Consulting services performed by HTA were limited to this report. The client requested no other services. PCB investigations, hazardous material audits, indoor air quality investigations, Phase I & II site assessments, and other general environmental consulting are additional services routinely performed by HTA. These services were not performed at this site. A general environmental audit may be performed to assess the need for additional environmental consulting services.

4.3. HTA's evaluations do not attempt to forecast or anticipate planned or unforeseen events which may negatively impact ACM condition. All conclusions and recommendations presented herein are based on visible conditions present at the time of sampling. Changes in material condition due to deterioration, unforeseen accidents, or planned events such as

– 5 – December 13, 2023 renovation or demolition may render the recommendations and conclusions presented in this report obsolete.

4.4. HTA cannot warrant that this facility does not contain hazardous materials in locations other than those noted in this report. If suspect materials are discovered during future repairs, demolition or renovation operations, all general work activities, which could impact the discovered suspect materials should cease until confirmation sampling and/or abatement options can be assessed.

• P . O . B O X 1 9 3 0 F A I R O A K S , C A L I F O R N I A • 9 5 6 2 8 - 1 9 3 0

P H O N E : 9 1 6 / 9 6 5 - 4 2 3 5 • F A X : 9 1 6 / 9 6 5 - 1 1 6 7 W W W . H T A E N G I N E E R I N G . C O M

EMSL Analytical, Inc.

464 McCormick Street San Leandro, CA 94577

Tel/Fax: (510) 895-3675 / (510) 895-3680 http://www.EMSL.com / sanleandrolab@emsl.com

092326405EMSL Order:

Customer ID: HTAS63

Customer PO:

Project ID:

Attention: Phone:Tolinda Thompson (916) 276-5118

Fax:HTA Science & Engineering, Inc. (916) 965-1167

Received Date:PO Box 1930 12/08/2023 9:30 PM

Analysis Date:Fair Oaks, CA 95628 12/11/2023

Collected Date: 11/30/2023

Project: FORT MASON BUILDING 201

Test Report: Asbestos Analysis of Bulk Materials via AHERA Method 40CFR 763 Subpart E

Appendix E supplemented with EPA 600/R-93/116 using Polarized Light Microscopy

Sample Description Appearance % Fibrous % Non-Fibrous

Non-Asbestos Asbestos

% Type

A-1

092326405-0001

None DetectedMatrix

Non-fibrous (Other)

70%

30%

Brown/White/Green

Non-Fibrous

Homogeneous

ELEVATOR FRAME

RIGHT

Inseparable paint / coating layer included in analysis

A-2

092326405-0002

None DetectedMatrix

Non-fibrous (Other)

70%

30%

Brown/White/Green

Non-Fibrous

Homogeneous

ELEVATOR FRAME

LEFT

Inseparable paint / coating layer included in analysis

Analyst(s)

Karina Martinez (2) Cecilia Yu, Laboratory Manager or Other Approved Signatory

EMSL maintains liability limited to cost of analysis . Interpretation and use of test results are the responsibility of the client. This report relates only to the samples reported above, and may not be reproduced, except in full, without written approval by EMSL. EMSL bears no responsibility for sample collection activities or analytical method limitations . The report reflects the samples as received.

Results are generated from the field sampling data (sampling volumes and areas, locations, etc.) provided by the client on the Chain of Custody. Samples are within quality control criteria and met method specifications unless otherwise noted. The above analyses were performed in general compliance with Appendix E to Subpart E of 40 CFR (previously EPA 600/M4-82-020 “Interim Method”) but augmented with procedures outlined in the 1993 (”final”) version of the method. This report must not be used by the client to claim product certification, approval, or endorsement by NVLAP, NIST or any agency of the federal government. Non- friable organically bound materials present a problem matrix and therefore EMSL recommends gravimetric reduction prior to analysis . Unless requested by the client, building materials manufactured with multiple layers (i.e. linoleum, wallboard, etc.) are reported as a single sample. Estimation of uncertainty is available on request.

Samples analyzed by EMSL Analytical, Inc San Leandro, CA NVLAP Lab Code 101048-3, WA C884

Initial report from: 12/11/2023 11:22:28

Page 1 of 1ASB_PLM_0008_0001 - 1.78 Printed: 12/11/2023 8:22 AM

OrderID: 092326405