3.a. - Lead and Asbestos Survey Report. Harkin's Slough. 10.2.2020.pdf

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TABLE OF CONTENTS

Section Page

1.0 INTRODUCTION

2.0 SITE DESCRIPTION

3.0 ASBESTOS BACKGROUND AND SURVEY METHODOLOGY

3.1 ASBESTOS BACKGROUND AND REGULATIONS

3.2 ASBESTOS SURVEY METHODOLOGY

4.0 ASBESTOS SURVEY RESULTS

4.1 CONFIRMED ASBESTOS-CONTAINING MATERIALS

4.2 NON-ACMS OR NON-SUSPECT MATERIALS

5.0 LEAD BACKGROUND AND SURVEY METHODOLGY

5.1 LEAD BACKGROUND AND REGULATIONS

5.2 LEAD SURVEY METHODOLOGY

6.0 LEAD SURVEY RESULTS

6.1 SURVEY RESULTS FOR LEAD TTLC ANALYSIS

7.0 CONCLUSIONS

7.1 ASBESTOS CONCLUSIONS

7.2 LEAD CONCLUSIONS

8.0 RECOMMENDATIONS

9.0 STATEMENT OF LIMITATIONS

SITE DIAGRAMS

Diagram 1 Asbestos and Lead Sample Locations – Site 1, Residence 1 Diagram 2 Asbestos and Lead Sample Locations – Site 1, Metal Building and Shed Diagram 3 Asbestos and Lead Sample Locations – Site 2, Residence 1 Diagram 4 Asbestos and Lead Sample Locations – Site 2, Residence 2 and Shed Diagram 5 Asbestos and Lead Sample Locations – Site 2, 4 Sheds

TABLES

Table 1 Asbestos Sample Log with Analytical Results Table 2 Lead Sample Log with Analytical Results

PHOTOGRAPHS

Asbestos & Lead Photograph Record

APPENDICES

Appendix A Personnel Certifications Appendix B Asbestos Analytical Laboratory Reports Appendix C Lead Analytical Laboratory Report

1.0 INTRODUCTION

The U.S. Department of Interior, Fish & Wildlife Service (USFWS) has retained EnviroApplications, Inc. (EAI) to conduct a Lead and Asbestos Building Survey (survey) to identify hazardous building materials scheduled to be disturbed during demolition activities. The property at 1487 Ranport Road (the Site) is part of the Harkin’s Slough Unit of Ellicott Slough National Wildlife Refuge in Watsonville, California, and is comprised of two sites including residences, sheds, a garage, a metal building and a barn. All structures are unoccupied and abandoned. The field portion of the survey took place on August 31st through September 2nd, 2020 and is comprised of two parts: an asbestos survey and a lead survey. The field portion of the survey was performed by a California-certified professional, Steve Rogers, a California Certified Site Surveillance Technician (CSST) and California Department of Public Health (CDPH) Lead Sampling Technician. The field work was supervised and this report was reviewed by Michael Benefield, a California Certified Asbestos Consultant (CAC) and a CDPH Inspector/Assessor. Personnel certifications are attached as Appendix A.

Asbestos Survey

The asbestos survey performed was comprised of a visual inspection and bulk sampling of potential asbestos-containing materials (ACMs). Bulk samples of potential ACMs were collected using destructive techniques in select representative locations. The scope of work for this survey did not include testing for airborne asbestos or asbestos in settled dust or soil. If a material was unable to be sampled (due to safety concerns or access issues), then it must be assumed to be an ACM and treated as such until sampling and analysis prove otherwise.

The objective of the survey was to identify, estimate quantities of, and assess the condition/friability of asbestos in accessible areas of the interior, exterior, and roof system of the subject buildings.

These objectives were met by completing the following tasks:

• Perform a visual inspection for suspect ACMs following Asbestos Hazard Emergency Response

Act (AHERA) sampling protocol as a guideline to identify sources of friable and non-friable ACMs;

• Homogenize, collect and analyze representative bulk samples of suspect material for asbestos content; and

• Prepare this report summarizing the inspection activities, findings, conclusions, and recommendations.

Lead Survey

The lead survey performed was comprised of a visual inspection, followed by bulk sampling of building components suspected of containing lead-containing paint (LCP) and/or lead-containing material (LCM). In 2005 an Environmental Site Assessment Survey was performed at the site, which included a limited number of composite lead-paint chip samples collected. From this survey, LCP was identified by collection and analysis of bulk samples of building components with suspected LCP or suspected LCM. EAI’s survey was performed to further identify all potential suspect building components from each building scheduled to be demolished. Destructive testing of building components with suspect LCP and LCMs was performed by sampling not only the painted layers, but the entire building component including the substrate. The purpose of this method of sampling was two-fold: identify building components with detectable levels of lead by the Total Threshold Limit Concentration (TTLC) and use the results of the TTLC analysis as a preliminary waste characterization tool to direct lead waste segregation/streaming during demolition activities.

The purpose of the lead survey was to determine in accessible areas the presence and general location of lead in suspect buildings materials and determine initial characterization of lead waste for the purposes of segregating onsite waste streams during demolition activities of the subject buildings.

These objectives were met by completing the following tasks:

• Perform a visual inspection for building components with suspect LCP/LCM following U.S.

Department of Housing and Urban Development (HUD) and CDPH guidelines;

• Test and analyze suspect building material for total threshold limit concentration of lead using TTLC analysis; and

• Prepare this report summarizing the inspection activities, findings, conclusions, and recommendations.

2.0 SITE DESCRIPTION

The sites at 1487 Ranport Road are part of the Harkin’s Slough Unit of Ellicott Slough National Wildlife Refuge in Watsonville, California. The site occupies the small valley formed by Harkin’s slough located on the west slope of the slough. The property was purchased by USFWS in the early 2000s to be included in the San Francisco Bay Wildlife Refuge Complex. Prior to the purchase of the property from the Farm Services Agency (FSA) the site was operated as a farm for approximately 40 years. The site consists of an entrance road (Ranport Road) that enters the property from the north and includes damaged, dilapidated, and abandoned structures. The structures include multiple residences, barns, and sheds. All structures have suffered some form of damage such as building degradation, collapsed roof, exposure to the elements, and/or vandalism or stripping of building materials.

For the purpose of this report, the sites are characterized as follows:

• Site #1:

o Residence 1: Main Residence o Metal Building o Garage

• Site #2:

o Residence 1 o Residence 2 o Barn o Sheds

Site #1

Residence 1

The unoccupied residence is approximately 3,170 square feet in size and reportedly built in 1980.

The property is heavily damaged and dilapidated with evidence of vandalism and stripping of building materials. The residence is one-story on a concrete foundation. The property is primarily comprised of wood construction with wood-framed above-grade walls. The exterior of the property is comprised of wood siding, wood and metal trim, wood-framed windows, and wood doors. A masonry unit block and mortar fence was observed along the west side of the property. The damaged roof is composed of nailed-on wood roof shingles with exposed holes and damage, exposing the vapor barrier paper and ceiling/roof insulation.

The residence is composed of a driveway, kitchen, living room, dining area, storage area, bedrooms, closets, and restrooms. The flooring throughout the building consists of various vinyl sheet floorings and carpet. Interior walls and ceilings are composed of textured drywall and joint compound, wood panels, and unfinished drywall and joint compound.

Metal Building

The vacant building is approximately 2,230 square feet and reportedly built in 1980. The building is in a heavily damaged and dilapidated state with evidence of vandalism and stripping of building materials. The building is comprised primarily of metal building materials with a concrete slab foundation. The building includes an office and restrooms. Interior walls and ceilings of the restrooms and office are composed of drywall and joint compound. The roof, which was observed to be partially collapsed, is comprised of metal. In addition, a partially collapsed shed, approximately 50 square feet in size is located west of the metal building and is composed of wood building materials.

Garage

The garage was reportedly built in 1980 and was approximately 1,480 square feet. At the time of inspection, the garage was observed to be completely collapsed. The garage appeared to be composed of primarily wood building materials.

Site #2

Residence 1

The unoccupied/abandoned residence is approximately 1,190 square feet in size and reportedly built in 1947. The property is in a heavily damaged and dilapidated state with evidence of vandalism and stripping of building materials. The interior of the property is covered in damaged building material dust and debris throughout. It should also be noted that the majority of the wall/drywall material within the residence was observed to be missing/removed. The residence is one-story on a raised wood foundation with a concrete landing at the front entry. The property is primarily constructed with wood construction and wood-framed above-grade walls. The exterior of the property is comprised of wood shingle siding, wood-framed windows, wood trim, and wood doors. The roof is composed of multilayer asphalt roof shingles with minor damage observed.

The residence is composed of a kitchen, living room, restroom, closets, and three bedrooms. Interior walls include drywall and joint compound, plaster, and fabric layers. Interior ceilings include drywall and joint compound and textured drywall and joint compound. Interior flooring consisted of vinyl floor tile and vinyl sheet flooring.

Residence 2

The unoccupied, abandoned residence is approximately 1,010 square feet in size and reportedly built in 1980. The property is in a heavily damaged and dilapidated state with evidence of vandalism and stripping of building materials. The interior of the property is covered in damaged building material with dust and debris throughout. It should also be noted that hazardous conditions were present in Room 1 at the northeast corner of the residence due to the presence of a wasp nest and, therefore, no sampling was performed in this room. The residence is one-story on a raised wood foundation. The property is primarily constructed with wood construction with wood framed above grade walls. The exterior of the property is comprised of transite and wood shingle siding, wood-framed windows, and wood doors. The roof is composed of multilayer asphalt roof shingles with minor damage observed.

The residence is composed of front patio, kitchen/dining area, living room, bedrooms, closets, and restrooms. The flooring within the residence includes various vinyl sheet floorings, carpet, and ceramic tile. Interior walls and ceilings are composed of drywall and joint compound.

In addition, a detached shed is present to the southeast of the residence. The shed is composed of primarily wood and vapor barrier paper. Access was limited due to hazardous conditions including a wasp nest on the shed.

Barn

The garage was reportedly built in 1980 and was approximately 1,480 square feet. At time of inspection, the garage was observed to be completely collapsed. Garage appeared to be composed of primarily wood building materials.

Sheds

Four empty sheds were inspected, each approximately 50 square feet in size and ranging in condition from collapsed to damaged. Three out of the four sheds were primarily constructed with wood and roof shingles. The fourth shed, located farthest to the south, was composed of wood and unfinished interior drywall walls. Access to the roof of the sheds was limited due to vegetation overgrowth. However, roof shingles were observed on the roof system of the collapsed shed.

3.0 ASBESTOS BACKGROUND AND SURVEY METHODOLOGY

3.1 Asbestos Background and Regulations

Background

Asbestos is a group of naturally occurring mineral fibers. Due to its durability and insulating quality, it was used in a wide variety of building products including structural fireproofing, pipe and duct insulation, plasters, roofing, floor tile, and vinyl floor sheeting. Adverse health effects have been associated with the inhalation of airborne asbestos fibers by asbestos industry workers.

The asbestos fibers that are tightly bound in building materials do not represent an exposure hazard unless disturbed in such a way that airborne fibers release (i.e., cutting, drilling, or sanding). By June of 1978, the U.S. Environmental Protection Agency (EPA) had effectively banned the use of asbestos in spray application products such as structural fireproofing and acoustic ceilings, pipe-lagging, joint compounds, and spackles. Asbestos is still used in the manufacture of non-friable products such as vinyl floor tile and roofing materials.

Regulations

In accordance with the EPA's National Emission Standards for Hazardous Air Pollutants (NESHAP) regulation and the San Diego Air Pollution Control District (SDAPCD), all facilities planned for renovation or demolition must be surveyed for ACMs prior to the planned renovation or demolition. Subsequent abatement or encapsulation of identified ACMs is also required.

Abatement requires removal to the greatest extent practical, preferably complete removal, disposal, and replacement, if necessary, of the ACM. Removal may require encapsulation of the structure, or portions throughout, to lock down or control residual fibers which may exist.

Regulatory agencies and municipal building agencies typically require removal of all ACMs prior to demolition or renovation. ACMs include friable ACMs; Category I non-friable ACMs, which have or will become friable or that have been subjected to sanding, drilling, grinding, cutting, or abrading; and Category II non-friable ACMs that may become or have become crumbled, pulverized, or reduced to powder by the forces expected to act on the material in the course of demolition or renovation.

The following is a summary of current state and federal regulations containing requirements related to the performance of building surveys for asbestos. These summaries are not intended to be all inclusive and do not contain every aspect of the regulations discussed. Regulations pertaining to the removal and disposal of ACMs are not included.

National Emission Standards for Hazardous Air Pollutants

Under NESHAP, 40 CFR Part 61, regulation, no visible emissions are allowed during building demolition or renovation activities which involve regulated asbestos-containing materials (RACMs). For this reason, all buildings must be surveyed for ACMs prior to demolition or renovation. The EPA and/or the local air quality management district, which implements EPA actions, must be notified prior to any building demolition even if no ACMs are present. RACM is defined as any material with an asbestos content of greater than one percent and is friable, or Category I non-friable ACM that has or will become friable, or Category II non-friable ACM that may become or will become crumbled, pulverized, or reduced to powder by the forces expected to act on the material in the course of demolition or renovation.

According to NESHAP, ACM is material containing more than one percent (1.0%) asbestos as determined using the methods specified in 40 CFR Part 763, Appendix A, Subpart E, Section 1, Polarized Light Microscopy (PLM). NESHAP classifies ACM as friable or non-friable. Friable ACM is ACM that, when dry, can be crumbled, pulverized, or reduced to powder by hand pressure.

Non-friable ACM is further classified as either Category I ACM or Category II ACM. The materials are distinguished by their potential to release fibers when damaged. Category I ACM includes asbestos-containing gaskets, packings, resilient floor coverings and mastics, and asphalt roofing products. Asphalt roofing products include built-up roofing, asphalt-containing membrane systems, asphalt shingles, asphalt-containing underlayment felts, asphalt-containing roof coatings and mastics, and asphalt-containing base flashings. Category II ACM includes all other non-friable ACM, such as asbestos cement shingles, asbestos cement tiles, and asbestos cement boards or panels. Category II ACMs are much more likely to release fibers when damaged.

If a material is analyzed as <1.0% asbestos through PLM analysis, it must be, at a minimum, 400-point counted to confirm it is less than 1.0% asbestos. Until the material is point counted, it must be considered ACM.

Asbestos Hazard Emergency Response Act

AHERA is a federal regulation requiring performance of asbestos surveys and the development of Asbestos Management Plans for all of the nation's primary and secondary schools. The general procedures mandated under AHERA are considered the industry standard and are used as a guideline for all surveys performed by EAI.

California Occupational Safety and Health Administration

Per California Occupational Safety and Health Administration (Cal/OSHA) standard Title 8 CCR 1529, ACMs are defined as any materials with an asbestos content greater than one percent (>1.0%). Work involving contact, disturbance, or removal of ACMs is classified as Class I, Class II, Class III, or Class IV work. The work classes are based upon the risk level of exposure.

Cal/OSHA prescribes specific engineering controls and work practices for each Class of ACM as follows:

• Class I This Class refers to ACMs identified as Thermal System Insulation (TSI) or surfacing (sprayed-on or troweled-on) materials. These materials are generally considered friable.

• Class II This Class refers to ACMs identified that are not Thermal System Insulation (TSI) or surfacing materials. These materials are generally considered non-friable.

• Class III This Class refers to repair and maintenance operations of all identified ACMs.

• Class IV This Class refers to incidental contact with ACMs such as work including custodial staff.

Cal/OSHA defines asbestos-containing construction material (ACCM), for the purpose of worker protection, as material containing greater than one tenth of one percent (>0.1%) asbestos by weight. Material that is greater than 0.1% but less than 1.0% asbestos is not considered hazardous asbestos waste and can be disposed of as regular construction material. For material to be confirmed as ACCM and not ACM, it must be, at a minimum, 400-point counted to verify the sample is less than 1.0% asbestos. For material to be confirmed as less than 0.1% asbestos, it must be, at a minimum, 1,000-point counted.

California Health and Safety Code

The California Health and Safety Code 25915 (former Connelly Bill) requires all building owners in the State of California to provide written notification to employees, tenants, and contractors of the known presence and location of ACCMs within their buildings. Some exclusions to the notification rule for restricted access areas are allowed. All documentation related to asbestos surveys (and air monitoring) must be made available to employees, tenants, or contractors for review. The California Health and Safety Code defines ACCMs as:

Asbestos materials with less than 1.0%, but greater that 0.10% asbestos. These ACMs require an abatement plan during demolition that is protective of worker health and safety. However, unlike an EPA classified ACM, ACCMs do not necessitate special disposal requirements.

The California Health and Safety Code also requires that a seller with any knowledge of ACMs on a property disclose such information or knowledge to other parties involved in a real estate transaction.

3.2 Asbestos Survey Methodology

Bulk Sampling for Asbestos

On August 31st and September 1st, 2020, the subject buildings were visually inspected and suspect asbestos materials were sampled in accordance with the methods presented in the Federal AHERA regulations (40 CFR, Part 763) as a guideline. Identified suspect materials were also physically assessed for friability and condition.

A total of 106 representative suspect bulk asbestos samples were collected from accessible areas of the interior and exterior of the subject buildings. The buildings’ materials appeared to be homogenous within specific areas and were sampled accordingly. The following is a list of the materials that were targeted:

• Textured drywall/joint compound

• Drywall/joint compound

• Wall panel mastic

• Vinyl sheet flooring and mastic

• Vapor barrier

• Roof shingles/paper

• Concrete masonry unit block and mortar

• Paper/fabric layers behind drywall

• Drywall (unfinished)

• Concrete slab/landing

• Multilayer wall paper

• Ceramic tile and grout adhesive

• Transite siding

• Vinyl floor tile and mastic

• Plaster

• Textured drywall ceiling

Bulk samples of suspect materials were collected to determine the asbestos content. The analytical results identify the percentage of each type of asbestos detected. AHERA sample criteria guidelines were followed to determine the appropriate number of samples collected per homogenous materials.

Samples approximately one-half square inch in size were collected of each suspect material.

Each sample was collected by removing the material using a chisel or other sharp instrument to cut away a representative piece. The sample of suspect material was placed in a plastic bag and quickly sealed to prevent material escape or the introduction of contamination from outside sources. A unique sample number was assigned to each sample.

In conducting the survey, personnel did not collect samples in inaccessible locations such as areas with hazardous or unsafe conditions. Materials not sampled and analyzed must be presumed to be

ACM.

Asbestos Laboratory Testing

The collected building material samples were submitted under legal chain-of-custody to Eurofins of Cary, North Carolina. Samples were analyzed for Asbestos Analysis of Bulk Materials via EPA 600/R-93/116 and EPA 600/M4-82/020 Methods using Polarized Light Microscopy (PLM).

Eurofins is an accredited laboratory, accredited under the National Institute of Standards and Technology's National Voluntary Laboratory Accreditation Program (NVLAP Lab Code #101768-0).

The PLM analysis is a visual estimation only. The lower limit of reliable detection (quantifiable) for asbestos using the PLM method is approximately one-percent (1.0%) by volume. Since PLM methodology cannot quantify the exact percentage of asbestos detected less than one-percent, it would identify these materials as <1.0%. Only materials containing no asbestos fibers are identified as “None Detected.

4.0 ASBESTOS SURVEY RESULTS

4.1 Confirmed Asbestos-Containing Materials

Bulk material samples were collected from representative homogeneous materials throughout the interior and exterior of the buildings. The sample locations are shown on the Site Diagrams (Diagrams 1-5). Photographs of building materials with confirmed ACM are provided on the Asbestos and Lead Photograph Record (Photographs). Materials sampled, sampling locations, descriptions of material and analytical results are summarized in Table 1. The analytical laboratory reports are attached (Appendix B).

The following lists the site number, building, and materials which are considered ACMs based on laboratory analytical results:

Site #1

Residence 1:

• Textured drywall and joint compound in walls and ceiling throughout

• Unfinished drywall and joint compound behind wood panels

• Brown wall panel mastic behind wood wall panels

• Blue and white vinyl sheet flooring and mastic in restrooms 1 and 2

• White vinyl sheet flooring and mastic in dining area and kitchen floor

Metal Building:

• Drywall and joint compound throughout walls and ceiling of office

Site #2

Residence 1:

• Drywall and joint compound in walls of rooms 1 and 2 and areas with remaining drywall and joint compound material

• Textured drywall ceilings in kitchen and living room

Residence 2:

• White and brown vinyl sheet flooring and mastic in living room, restrooms, and rooms 1 and 2

• Yellow exterior transite siding from exterior walls of property

If additional materials are discovered and will be impacted/disturbed by demolition activities, they should either be sampled/tested prior to disturbance or assumed and treated as positive for asbestos. EAI’s inspection was limited to accessible and visible areas.

The ACMs identified range from friable to non-friable and range in condition, from good to severely damaged. If any of the above-mentioned or assumed ACMs are to be damaged/disturbed/removed, these activities must be performed by a Cal/OSHA registered asbestos abatement contractor and properly handled and treated in accordance with the EPA NESHAP, Cal/OSHA, and the local Monterey Bay Unified Air Pollution Control District.

4.2 Non-ACMs or Non-Suspect Materials

The following materials were observed in the building and are not considered suspect ACMs.

This is not meant as a complete listing of non-ACM building materials observed within the structure, but provided to indicate that these materials were considered. These materials include:

• Materials not considered part of the building (e.g., shelves)

• Glass and windows

• Plastic

• Metal

• Fabric

5.0 LEAD BACKGROUND AND SURVEY METHODOLGY

5.1 Lead Background and Regulations

Background

Lead is a bluish-gray, non-combustible metal that occurs naturally in the earth’s crust. Lead is malleable, ductile, and resistant to corrosion. These basic properties led to the use of lead, historically, as a paint additive. Lead is a highly toxic metal that was used for many years in products found in and around residential and commercial buildings. Lead may cause a range of health effects, from behavioral problems and learning disabilities, to seizures and death. Children six years old and under are most at risk due to the developmental stage of their bodies. The primary sources of lead exposure, based on research, include deteriorating lead-based paint in buildings, lead contaminated soil, and lead contaminated dust.

In pre-1955 paint, lead comprised 25% to 75% of the paint’s contents. In 2009, the Consumer Product Safety Commission (CPSC) ruled that consumer paint could not contain more than 0.009% lead.

Regulations

U.S. Environmental Protection Agency, Toxic Substances Control Act, Section 403

The federal lead-based paint standard is defined as paint or other surface coatings containing lead at or above 1.0 mg/cm2, 0.5% by weight, or 5,000 parts per million (ppm).

California Division of Occupational Safety and Health

Cal/OSHA Title 8, CCR Section 1532.1 details requirements for employees who may be exposed to lead during construction work including, but not limited to, demolition of structures where any concentration of lead is present, and transportation and disposal of LCP.

California Department of Toxic Substance Control, Resource Conservation and Recovery Act

Department of Toxic Substance Control (DTSC) Hazardous Waste Characterization under California State regulations as outlined in Title 22 of the California Code of Regulations (CCR).

5.2 Lead Survey Methodology

Sampling for Lead

On September 2, 2020, bulk samples of the predominant suspect lead building materials were collected. Each sample collected included all painted layers and the building component substrate. Sampling was performed on accessible, suspect LCP/LCM building components from the interior and exterior of buildings. A total of 22 bulk samples were collected and submitted for TTLC analysis. TTLC analysis was utilized to determine total threshold lead concentrations of building components in milligrams per kilogram (mg/kg). The lead concentrations detected identified the presence and concentration of lead as a whole solid. The reported levels were then utilized as a hazardous waste pre-screening tool prior to demolition activities for purposes of waste segregation/streaming.

Following a visual inspection and assessment of building materials, the sampling locations of suspect LCP/LCM was determined based on identifying homogenous and representative building components suspected of containing lead. During the lead inspection, sample collection was not performed in every room or of every painted/varnished/coated/stained building component. A representative sample of a similar, homogenous building material (i.e., same color, substrate, etc.)

was collected per structure or applicable area.

Each sample was collected by removing the material using a portable drill motor and a 1-inch hole saw bit to remove a representative sample of the building material including the painted layers and the substrate. and the sample was placed in a plastic bag and quickly sealed to prevent material escape or the introduction of contamination from outside sources. A unique sample number was assigned to each sample.

Lead Laboratory Testing

The collected building material samples were submitted under legal chain-of-custody to AIH Laboratory of Anaheim, California. Samples were analyzed for Total Threshold Limit Concentration – Lead (Pb) via EPA 7000B Method. AIH is an accredited laboratory, accredited under the American Industrial Hygiene Association, Laboratory Accreditation Program (AIHA LAP) LLC Accredited Laboratory for Environmental Lead Laboratory ISO/IEC 17025:2005 (Lab

ID #203869).

The TTLC method is used when determining the hazardous waste characterization under California State regulations as outlined in Title 22 of the California Code of Regulations (CCR).

The intent of the leachate procedures is to simulate the conditions that may be present in a landfill where water may pass through the land filled waste and travel on into the groundwater carrying the soluble materials with it. This analysis determines the total concentration of lead in a sample.

The results of this analysis can be used to determine if analysis for TCLP or STLC level is necessary.

6.0 LEAD SURVEY RESULTS

6.1 Survey Results for Lead TTLC Analysis

A total of 22 lead bulk samples were collected from the Site. The sampling locations are shown on Site Diagrams (Diagrams 1-5). Photographs of representative material samples with lead detected are provided on the Asbestos & Lead Photograph Record. A summary of the lead survey results of the TTLC analysis, sampling locations, material descriptions and initial pre-demolition waste characterization determination and/or recommendation is provided in Table 2. The analytical laboratory report is attached (Appendix C).

The following is a summary of building components identified with detectable concentrations of lead and the associated initial pre-demolition waste classification and/or recommendation. A specific classification of LCP or LCM cannot be made due to the nature of sampling – the bulk material sample’s lead concentration may be diluted, because the entire building component, including substrate and not just a paint chip, was analyzed using TTLC. The sampling was performed of the entire building component including the substrate and not of a scraped off direct layer of paint, therefore, lead levels are diluted and building components with detectable levels of lead are reported as lead containing and not further identified as LCP or LCM. This sampling was performed to identify building components which may have lead and to be used as an initial pre-demolition screening tool for waste segregation during demolition activities.

The following is a summary of locations and building components that were reported with lead using the TTLC analysis and EAI’s associated initial classifications using either non-hazardous, hazardous or recommended for further TCLP and/or STLC analysis directly from waste pile after demolition:

Site #1

Residence 1:

• Analysis of white painted wood exterior siding on exterior walls of residence, by TTLC reported a lead concentration of 28,258 mg/kg. Waste containing >1,000 mg/kg lead is defined as hazardous waste. This material should be segregated as a separate waste stream and should be disposed of as lead hazardous waste.

• Analysis of yellow/white steel exterior siding from exterior walls of building, by TTLC reported a lead concentration of 38 mg/kg. Waste streams with results <50 mg/kg are defined as non-hazardous waste.

• Analysis of brown steel exterior flashing and roof/ceiling beams from building by TTLC a lead concentration of 319 mg/kg. Waste streams with results >100 mg/kg and <1,000 mg/kg must be further characterized by TTLC and/or STLC analysis prior to disposal.

Shed at Metal Building:

• Analysis of brown painted wood walls within shed, by TTLC reported a lead concentration of 20 mg/kg. Waste streams with results <50 mg/kg are defined as non-hazardous waste.

Site #2

Residence 1:

• Analysis of white painted interior plaster walls within residence, by TTLC reported a lead concentration of 662 mg/kg. Waste streams with results >100 mg/kg and <1,000 mg/kg must be further characterized by TTLC and/or STLC analysis prior to disposal.

• Analysis of white wood painted trim from the interior and exterior of the residence, by TTLC reported lead concentrations of 7,827 mg/kg and 10,394 mg/kg, respectively.

Waste containing >1,000 mg/kg lead is defined as hazardous waste. This material should be segregated as a separate waste stream and should be disposed of as lead hazardous waste.

• Analysis of brown painted wood exterior shingles, by TTLC reported a lead concentration of 1,535 mg/kg. Waste containing >1,000 mg/kg lead is defined as hazardous waste. This material should be segregated as a separate waste stream and should be disposed of as lead hazardous waste.

• Analysis of yellow painted exterior transite shingles from exterior walls of residence, by

TTLC reported a lead concentration of 116 mg/kg. Waste streams with results >100 mg/kg and <1,000 mg/kg must be further characterized by TTLC and/or STLC analysis prior to disposal.

• Analysis of white painted drywall within the residence, by TTLC reported a lead concentration of 106 mg/kg. Waste streams with results >100 mg/kg and <1,000 mg/kg must be further characterized by TTLC and/or STLC analysis prior to disposal.

• Analysis of white painted wood trims within the residence, by TTLC reported a lead concentration of 278 mg/kg. Waste streams with results >100 mg/kg and <1,000 mg/kg must be further characterized by TTLC and/or STLC analysis prior to disposal.

• Analysis of white painted wood exterior shingles from exterior walls of residence, by TTLC reported a lead concentration of 10,394 mg/kg. Waste containing >1,000 mg/kg lead is defined as hazardous waste. This material should be segregated as a separate waste stream and should be disposed of as lead hazardous waste.

7.0 CONCLUSIONS

7.1 Asbestos Conclusions

The following materials are considered ACMs based on observations and laboratory analytical results:

Site #1

Residence 1:

• Textured drywall and joint compound in walls and ceiling throughout

• Unfinished drywall and joint compound behind wood panels

• Brown wall panel mastic behind wood wall panels

• Blue and white vinyl sheet flooring and mastic in restrooms 1 and 2

• White vinyl sheet flooring and mastic in dining area and kitchen floor

• Drywall and joint compound throughout walls and ceiling of office

Site #2

Residence 1:

• Drywall and joint compound in walls of rooms 1 and 2 and areas with remaining drywall and joint compound material

• Textured drywall ceilings in kitchen and living room

• White and brown vinyl sheet flooring and mastic in living room, restrooms and rooms 1 and 2

• Yellow exterior transite siding from exterior walls of property

7.2 Lead Conclusions

The following building components had detectable levels of lead. However, based on reported TTLC levels, the below listed building components are categorized as non-hazardous waste:

Site #1 - Metal Building:

• Yellow/white steel exterior siding from exterior walls of building

Site #1 - Shed at Metal Building:

• Brown wood walls within shed

The following building components had detectable levels of lead, and based on reported TTLC levels, the below listed building components are categorized as hazardous waste:

Site #1 - Residence 1:

• White painted wood exterior siding on exterior

Site #2 - Residence 1:

• White painted wood trim from the interior and exterior of the residence

• Brown wood exterior shingles

Site #2 - Residence 2:

• White painted wood exterior shingles from exterior walls

The following building components had detectable levels of lead, and based on reported TTLC levels, further analysis by TCLP and/or STLC should be performed following demolition activities to characterize the generated waste stream:

Site #1 – Metal Building:

• Brown steel exterior flashing and roof/ceiling beams

Site #2 – Residence 1:

• White painted interior plaster walls

Site #2 – Residence 2

• Yellow painted exterior transite shingles from exterior walls

• White painted drywall within the residence

• White painted wood trims within the residence

8.0 RECOMMENDATIONS

• Based on several hazard assessment factors including: physical condition, friability, accessibility, area activity, air movement, and disturbance potential, EAI recommends that access to the buildings with ACM and/or lead should be restricted/limited to licensed abatement firms utilizing proper personal protective equipment (PPE).

• Due to the damaged condition of buildings with visible dust and debris throughout and confirmed ACM, only CSLB licensed and Cal/OSHA registered asbestos abatement contractor firms should be contracted to remove identified ACM hazardous building materials. If additional suspect materials are uncovered during renovations that are not listed in this report, they should be assumed positive and handled accordingly unless additional testing is performed.

• Based on the presence of lead in various buildings, all lead work must follow the California Code of Regulations, Title 8, Section 1532.1 et seq and worker protection requirements for employees must follow the Lead-in-Construction Standard. Employees who engage in lead-related construction work, including construction, demolition, renovation and repair. Contractors disturbing more than 100 square feet or more than 100 linear feet of lead-containing materials must take steps to prevent worker exposures to lead and are required to notify the Department of Industrial Relations at least 24 hours prior to beginning work.

• EAI also recommends abatement contractors confirm the hazardous material quantities during a pre-bid job walk prior to bidding. This document is a guidance document and, because all material could not be accessed, should not be considered a bidding document.

Contractors should be asked to provide a unit cost for abatement materials in the event more material is found than estimated.

• Asbestos wastes must be handled and disposed of in accordance with the federal Toxic

Substances Control Act, 40 C.F.R. § 763. Other applicable laws and regulations include the Clean Air Act (NESHAP) and California Code of Regulations, title 22, division 4.5.

Hazardous asbestos waste must be transported by a registered hazardous waste transporter to a permitted treatment, storage, or disposal facility and the waste must be accompanied by a uniform hazardous waste manifest. Waste must be disposed of at a landfill authorized to accept asbestos wastes by its Regional Water Quality Control Board. Friable asbestos-containing waste must be disposed of as RACM waste and in as California Specific Hazardous waste under a Waste Shipment Record and a California Uniform Hazardous Waste Manifest.

• Disposal and handling of lead waste must follow local, state and federal regulations such as the California Department of Toxic Substances Control (DTSC) requirements for proper lead disposal. Lead is a federally regulated hazardous waste under the Environmental Protection Agency’s (EPA’s) Resource Conservation and Recovery Act (RCRA). Materials identified as RCRA hazardous waste or building materials recommended for additional TCLP analysis should be segregated and stored properly into specific waste streams/piles during demolition activities. Identified hazardous materials should be segregated properly. Generated waste must be disposed of properly after further waste characterization profiling has been performed.

https://www.ecfr.gov/cgi-bin/text-idx?SID=aa3a160166fdcd87fd343d3f53f12af5&mc=true&node=pt40.34.763&rgn=div5 https://www.ecfr.gov/cgi-bin/text-idx?SID=aa3a160166fdcd87fd343d3f53f12af5&mc=true&node=pt40.34.763&rgn=div5 https://www.arb.ca.gov/enf/asbestos/asbestos.htm https://www.waterboards.ca.gov/water_issues/programs/land_disposal/walist.shtml

9.0 STATEMENT OF LIMITATIONS

The conclusions and recommendations contained in this report/assessment are based upon professional opinions with regard to the subject matter. These opinions have been arrived at in accordance with currently accepted standards and practices applicable to this location and are subject to the following inherent limitations:

• The material estimates provided herein are gross estimates of materials based on observations made, analyses performed, and opinions of qualified expert professionals.

• The data and findings presented in this report are valid as of the dates when the investigations were performed. The passage of time, manifestation of latent conditions, or occurrence of future events may require further exploration at the site, analysis of the data, and reevaluation of the findings, observations, and conclusions expressed in the report.

• The data reported and the findings, observations, and recommendations expressed in the report are limited by the Scope of Work.

• Unless otherwise stated in the report, because of the limitations stated above, the findings observations, and recommendations expressed by EAI in this report are not, and should not be, considered an opinion concerning the compliance of any past or present owner or operator of the site with any federal, state or local law or regulation.

• No warranty or guarantee, whether express or implied, is made with respect to the data or the reported findings, observations, and conclusions, all of which, however, accurately reflect site conditions in existence at the time of investigation.

• EAI reports present professional opinions and findings of a scientific and technical nature.

While attempts were made to relate the data and findings to applicable environmental laws and regulations, the report shall not be construed to offer legal opinion as to the requirements of, nor compliance with, environmental laws, rules, regulations or policies of federal, state or local governmental agencies. Any use constitutes acceptance of the limits of EAI’s liability. EAI’s liability extends only to those parties contracted to complete this project and not to any other parties who may obtain the Report. Issues raised by the report should be reviewed by appropriate legal counsel.

SITE DIAGRAMS

Notes ASBESTOS AND LEAD SAMPLE

LOCATIONS

SITE 1, RESIDENCE 1

1487 Ranport Road Watsonville, CA

Date: 09-28-2020 Project No.: 01.DOIASB1.20 Scale: None Diagram: 1

11A: Corresponds to asbestos sample location in Table 1 Pb-01: Corresponds to lead sample location in Table 2.

2831 Camino Del Rio South

Suite 214 San Diego, CA 92108

SITE 1, METAL BUILDING AND SHED

Date: 09-28-2020 Project No.: 01.DOIASB1.20 Scale: None Diagram: 2

15C: Corresponds to asbestos

Pb-07: Corresponds to lead sample location in Table 2.

*At time of inspection, garage was collapsed. Collapsed materials were inspected, no suspect asbestos or lead materials were observed, and therefore, no garage samples were collected.

2831 Camino Del Rio South

SITE 2, RESIDENCE 1

Date: 09-28-2020 Project No.: 01.DOIASB1.20 Scale: None Diagram: 3

33C: Corresponds to asbestos

Pb-17: Corresponds to lead sample location in Table 2.

*Almost all wall drywall is missing/removed.

2831 Camino Del Rio South

SITE 2, RESIDENCE 2 AND SHED

Date: 09-28-2020 Project No.: 01.DOIASB1.20 Scale: None Diagram: 4

22A: Corresponds to asbestos

Pb-15: Corresponds to lead sample location in Table 2.

*At time of inspection, shed roof was inaccessible due to wasp nest. In addition, access to room 1 at northeast end of residence was also inaccessible due to a wasp nest.

2831 Camino Del Rio South

SITE 2, 4 SHEDS

Date: 09-28-2020 Project No.: 01.DOIASB1.20 Scale: None Diagram: 5

37B: Corresponds to asbestos

Pb-23: Corresponds to lead sample location in Table 2.

*At time of inspection, Shed 1 was collapsed and roof materials were accessible to sample. Roofing materials was not accessible from Sheds 2-4 due to vegetation overgrowth.

2831 Camino Del Rio South

TABLES

DATE

COLLECTED SAMPLE ID SITE #/BUILDING SAMPLE

LOCATION

HOMOGENOUS

AREA MATERIAL DESCRIPTION GENERAL MATERIAL

LOCATION ANALYTICAL RESULTS ESTIMATED

QUANTITY*

NESHAP

CATEGORY CONDITION

8/31/2020 01A Site #1 Residence 1 Living Room Ceiling

8/31/2020 01B Site #1 Residence 1 Dining Area West Wall

8/31/2020 01C Site #1 Residence 1 Hallway Under Wood Wall

8/31/2020 01D Site #1 Residence 1 Room #3 North Wall

8/31/2020 01E Site #1 Residence 1 Room #5 Ceiling

8/31/2020 01F Site #1 Residence 1 Room #4 South Wall

8/31/2020 01G Site #1 Residence 1 Room #6 East Wall

8/31/2020 02A Site #1 Residence 1 Living Room Ceiling

8/31/2020 02B Site #1 Residence 1 Dining Area West Wall

8/31/2020 02C Site #1 Residence 1 Hallway Wall

8/31/2020 02D Site #1 Residence 1 Room #3 North Wall

8/31/2020 02E Site #1 Residence 1 Room #5 Ceiling

8/31/2020 02F Site #1 Residence 1 Room #4 South Wall

8/31/2020 02G Site #1 Residence 1 Room #6 East Wall

8/31/2020 03A Site #1 Residence 1 Living Room West Wall

8/31/2020 03B Site #1 Residence 1 Living Room South Wall

8/31/2020 03C Site #1 Residence 1 Dining Area Southeast Wall

8/31/2020 04A Site #1 Residence 1 Dining Area Southeast Wall

8/31/2020 04B Site #1 Residence 1 Dining Area Southwest Wall

8/31/2020 04C Site #1 Residence 1 Hallway Wall

8/31/2020 05A Site #1 Residence 1 Restroom #1 Floor

8/31/2020 05B Site #1 Residence 1 Restroom #2 Floor

8/31/2020 06A Site #1 Residence 1 Dining Area East Floor

8/31/2020 06B Site #1 Residence 1 Kitchen Floor

8/31/2020 06C Site #1 Residence 1 Dining Area South Floor

8/31/2020 07A Site #1 Residence 1 Restroom #4 Floor

8/31/2020 07B Site #1 Residence 1 Restroom #3 Floor

8/31/2020 08A Site #1 Residence 1 East Side

8/31/2020 08B Site #1 Residence 1 West Side

8/31/2020 08C Site #1 Residence 1 Southeast Side

5 Blue/White VSF and mastic

Restrooms 1 and 2 Floors

VSF: 25% CH

Mastic: 3%1 200 sf Friable -

RACM Good

4 Brown Wall Panel Mastic

Dining Area/Hallway Walls 2% CH

Unfinished Drywall and

Joint Compound Behind Wood Panels

Living and Dining Room Walls

Drywall: ND Joint Compound: 2%

Drywall/Joint Compound <1%

900 sf Friable Signficantly Damaged

2,800 sf Category II Non-Friable Good

9,000 sf Friable -

RACM

Signficantly Damaged

9,000 sf Friable -

RACM

TABLE 1

ASBESTOS SAMPLE LOG WITH ANALYTICAL RESULTS

Harkin's Slough Unit 1487 Ranport Road

Watsonville, CA

1 Textured Drywall and Joint Compound

Walls/Ceiling Throughout

Texture: 2% CH Drywall/Joint Compound:

<1% CH

2 Texture on Drywall Walls/Ceiling Throughout Texture: 2% CH Signficantly

Damaged

6 White VSF and mastic Dining Area and Kitchen Floor

VSF: 25% CH

Mastic: 3%1 800 sf Friable -

RACM Good

7 Orange and white VSF and mastic

Restrooms 3 and 4 Floor ND NA NA NA

NAVapor barrier Exterior Walls ND NA NA8

LOCATION

HOMOGENOUS

AREA MATERIAL DESCRIPTION GENERAL MATERIAL

LOCATION ANALYTICAL RESULTS ESTIMATED

QUANTITY*

NESHAP

CATEGORY CONDITION

TABLE 1

ASBESTOS SAMPLE LOG WITH ANALYTICAL RESULTS

Harkin's Slough Unit

8/31/2020 09A Site #1 Residence 1 Roof Northeast Side

8/31/2020 09B Site #1 Residence 1 Roof Northwest Side

8/31/2020 09C Site #1 Residence 1 Roof Southeast Side

8/31/2020 10A Site #1 Residence 1 West Side of House

8/31/2020 10B Site #1 Residence 1 West Side of House

8/31/2020 11A Site #1 Residence 1 Northwest Side

8/31/2020 11B Site #1 Residence 1 Southwest Side

8/31/2020 14A Site #1 Metal Building Southeast Side

8/31/2020 14B Site #1 Metal Building North Side

8/31/2020 15A Site #1 Metal Building Restroom 1 South Wall

8/31/2020 15B Site #1 Metal Building Restroom 1 North Wall

8/31/2020 15C Site #1 Metal Building Restroom 2 South Wall

8/31/2020 16A Site #1 Metal Building Office South Wall

8/31/2020 16B Site #1 Metal Building Office West Wall

8/31/2020 16C Site #1 Metal Building Office Center Ceiling

9/1/2020 17A Site #2 Residence 2 Kitchen Southwest Floor

9/1/2020 17B Site #2 Residence 2 Kitchen Northeast Floor

9/1/2020 17C Site #2 Residence 2 Kitchen Southeast Floor

9/1/2020 18A Site #2 Residence 2 Kitchen Southeast Wall

9/1/2020 18B Site #2 Residence 2 Room 2 Northeast Wall

9/1/2020 18C Site #2 Residence 2 Room 2 West Wall

9/1/2020 18D Site #2 Residence 2 Restroom 2 Ceiling

9/1/2020 18E Site #2 Residence 2 Room 3 North Wall

9/1/2020 19A Site #2 Residence 2 Room 1 Floor at Entry

9/1/2020 19B Site #2 Residence 2 Restroom 1 Floor

9/1/2020 19C Site #2 Residence 2 Restroom 2 Floor

9/1/2020 20A Site #2 Residence 2 Kitchen East Wall

9/1/2020 20B Site #2 Residence 2 Kitchen Northeast Wall

9/1/2020 20C Site #2 Residence 2 Kitchen North Wall

9 Roof shingle and paper under wood shingles Roof ND NA NA NA

NA NA

11 Concrete slab Slab throughout property ND NA NA NA

10 CMU block and mortar West side of house ND NA

Restroom walls and ceiling

Office walls and ceiling

Drywall and joint compound

ND

ND

Drywall: ND Joint Compound: 2% CH Drywall/Joint Compound:

<1% CH

Concrete slab

Brown drywall and joint compound

18 Drywall and joint compound

Walls and ceiling throughout ND NA NA NA

NA

NA

Damaged

17 White VSF and mastic Dining, kitchen and patio floor ND NA NA NA

NA

NA

400 sf

NA

NA

Friable -

RACM

Slab throughout property

Friable - RACM Damaged

20 Multilayer wall paper Kitchen ND NA NA NA

19 White/brown VSF and mastic

Flooring in living room, restrooms, rooms 1 and 2

VSF: 25% CH

Mastic: 3%1 800 sf

LOCATION

HOMOGENOUS

AREA MATERIAL DESCRIPTION GENERAL MATERIAL

LOCATION ANALYTICAL RESULTS ESTIMATED

QUANTITY*

Harkin's Slough Unit

9/1/2020 21A Site #2 Residence 2 Kitchen at Sink

9/1/2020 21B Site #2 Residence 2 Kitchen at Sink

9/1/2020 21C Site #2 Residence 2 Kitchen at Sink

9/1/2020 22A Site #2 Residence…