ADDEN2~3.PDF

Asbestos / Lead Limited Renovation Survey

San Bernardino County Department of Public Health

451 East Vanderbilt Way San Bernardino, CA 92408

Prepared for:

Servpro South Redlands

C/O Allison Padgett

Prepared by:

Charles Taylor Environmental Technical Services

301 Merritt 7 2nd Floor

Norwalk, CT 06851 Email:enviro@charlestaylor.com

Date:

04/10/2025

Project Number, Claim #:

2128393, PO5925815

mailto:enviro@charlestaylor.com

Table 1. Asbestos Results – 451 East Vanderbilt Way, San Bernardino, CA Project/Claim # 2128393, PO 592515

Sample Number Material Description Material Location Material Condition/

Friability/% Damage Analytical

Result Estimated Quantity

A01-A04 Wallboard, Joint Compound Men’s Restroom, Hallway, Closet, Open Space Good/NF NAD 2,800 ft2

* Additional laboratory analysis, reporting and/or testing may be required per local regulatory agency.

N/A: Not applicable NAD: Asbestos not detected in quantifiable concentrations.

F/Friable: Material that, when dry, may be easily crumbled, pulverized, or reduced to powder by hand pressure.

NF/Non-friable: Material that, when dry, may not be crumbled, pulverized, or reduced to powder by hand pressure.

Table 2. Lead Results – 451 East Vanderbilt Way, San Bernardino, CA Project/Claim # 2128393, PO 592515

Sample Number Location Component/Substrate Condition Color Result

L-01 Closet #1 Wall – Wallboard Intact White <0.1 NEG

L-02 Hallway Floor – Ceramic Intact Tan <0.1 NEG

Lead-Based Paint (LBP): Paint or other surface coating that contains lead more than 1.0 milligrams per centimeter squared (mg/cm2) or 5,000 parts per million (0.7 or 600 parts per million for Los Angeles County). LBP removal and disposal must be performed in accordance with CDPH Regulations as well as California OSHA requirements.

Lead-Containing Paint (LCP): Painted material or surfaces containing lead levels between 0.1 and 1.0 mg/cm2 or 600 to 5000 ppm of lead. LCP removal and disposal must be performed in accordance with California OSHA regulations and can be handled by a regular contractor who has prepared a California OSHA lead compliance plan/program for the protection of its workers. LCP is not a hazard to occupants per the EPA, HUD, and Cal/DPH and thus not regulated by those agencies.

Lead-Safe Paint (LSP): Painted material or surfaces containing lead levels by XRF as <0.1 mg/cm2 or <90 ppm by FAA is equivalent to the lead amount in current cans of paint sold over the counter throughout the US (approved by the Consumer Product Safety Commission).

Charles Taylor Environmental highly recommends that a qualified abatement contractor perform work where lead concentration is equal to or above 600 parts per million and/or 1.0 milligram per square centimeter or where regulated levels of lead are identified.

1 Introduction The purpose of this report is to establish the findings of the Limited Renovation Survey performed at the subject site. The survey was performed to determine asbestos and/or lead content, if any, within the materials that may be disturbed during limited renovations at the subject property.

Materials that may possibly contain asbestos/lead, yet not discussed within this report must be presumed to be Asbestos Containing Material (ACM) or Lead-based Paint (LBP) until laboratory analysis proves otherwise.

The following items provide the general parameters and scope of this survey report:

• Inspected by: Kyle Gamez

• CSST Certification #, CDPH Certification #: 10-4616, LRC-00003113

• Scope of Inspection Areas: Men’s Restroom, Hallway, Closet, Open Space

• This is a modified survey and results are limited to the specific areas and materials sampled. This report is not valid for use outside of the specific areas slated for renovation at this exact time or by individuals not associated with the currently proposed renovation work.

2 Field Survey and Analytical Methodology

2.1 Asbestos

Bulk samples of suspect ACMs were obtained by cutting small pieces of the material and placing the bulk pieces into labeled sample containers. To ensure the samples are representative of materials in the building, bulk samples were cut (where feasible) to a depth such that the entire thickness of the suspect ACM was sampled. Sampling tools were cleaned by wiping with disposable wet cloths after each sample was collected to prevent cross-contamination of asbestos fibers, if present. Sampling locations and material types were recorded on the sample location diagram and chain-of-custody sheets, which are provided in the attachments.

The bulk samples were transported under chain-of-custody to AIH Laboratory for analysis. AIH is a participating laboratory in the National Institute of Standards and Technology (NIST)-administered National Voluntary Laboratory Accreditation Program (NVLAP). (NVLAP), Certification Number 500079-0. In California, laboratories should have dual certification under the California Water Boards, Environmental Lab Accreditation Program (ELAP). Laboratory testing was conducted in compliance with Appendix A, Subpart F, 40 CFR Part 763, Section 1, Polarized Light Microscopy. All bulk samples submitted for testing were analyzed for asbestos content by PLM using "EPA Interim Method #600/R-93/116 (polarized light microscopy with optical dispersion staining)". See attached analytical report for address and phone number of the laboratory.

2.2 Lead

The procedures followed during the inspection are based on the highest industry standards used for residential properties which can be found in the United States Environmental Protection Agency (EPA) “Lead: Renovation, Repair and Painting Guidelines” (EPA 40 CFR Part 745, April 22, 2008 - Part II). The following is a general description of sampling activities: Lead sampling painted/coated surfaces that will be impacted by emergency repair and renovation activities were identified and sampled accordingly. The purpose of the inspection was solely to identify surface coatings that are lead-based paint (LBP) or lead-containing paint (LCP). Surfaces not slated for removal were not sampled and MUST be assumed to contain LBP unless further testing confirms the absence of regulated levels of lead in paint. Sampling of painted/coated surfaces with suspect LBP/LCP were completed by removal of approximately 2 square inches of paint from accessible and suspect painted/coated surfaces. If XRF analysis was performed, sampling was completed using an X-Ray Fluorescence Analyzer (XRF). The sampled surfaces may include, but not limited to, the following: walls, baseboards, window components, door components, crown molding, wainscoting, wood flooring varnish, eaves, stairwell rails, etc.

Note that both the US EPA and the California Department of Public Health (CDPH Title 17 California Code of Regulations) define LBP as any paint or other surface coating containing an amount of lead equal to or exceeding 1.0 milligram per square centimeter (mg/cm2) surface area of lead or 0.5 % lead by weight. In California, Title 17 regulates residential and public buildings.

“Public building” means a structure, or part of a structure, and its land, which is generally accessible to the public, including but not limited to, schools, daycare centers, museums, airports, hospitals, stores, convention centers, government facilities, office buildings and any other building which is not an industrial building or a residential building. LBPs are regulated in large part by the intent of the projects. If the LBP is disturbed incidental to a renovation, then EPA RRP applies. If the LBP is disturbed to abate a lead hazard, then all requirements of the CDPH Title 17 are applicable.

The California Division of Safety and Health (DOSH) or Cal/OSHA regulates all construction-related work where an individual may be exposed to lead, regardless of the lead concentration in paint or other surface coatings. Objective data showing that a specific paint or coating contains less than 0.06 % lead by weight (equivalent to 600 parts per million [ppm]) constitutes a “negative initial determination” whereby that paint/coating may be “installed” or otherwise handled in an intact state by non-protected/trained personnel. However, any other activities such as cutting, sanding, scraping, manual demolition, etcetera, require compliance with Cal/OSHA Title 8 CCR Section 1532.1 irrespective of lead content.

All lead laboratory testing was conducted in compliance with US EPA Method SW 846 3050B/7000B flame atomic absorption spectrometry analysis by the laboratory listed above. See attached analytical report for address and phone number as needed.

3 Results of Analysis

3.1 ASBESTOS

Quantifiable detection limits using this type of analysis are approximately one percent. For materials in which asbestos is detected, but at levels below one percent, the result is reported as “<1%,” but not further quantified. For those materials where asbestos was not detected, even in trace amounts, results are reported as non-detect (ND). Materials containing one-tenth of one percent or greater asbestos (> 0.1%) are considered asbestos-containing construction materials (ACCMs) according to California Occupational Safety and Health Administration (OSHA) regulations, and materials containing greater than one percent (>1%) asbestos are considered to be ACMs according to federal regulations.

Homogeneous material is considered NOT to contain Asbestos ONLY if the results of ALL samples required to be collected from the area show asbestos in amounts of less than the regulated amount (<0.1% in California). A homogeneous area shall be determined to contain Asbestos (ACM) based on a finding that the results of at least one sample collected from that area shows that asbestos is present (40 CFR 763.87). Laboratory results and chain of custody are attached.

A summary of materials sampled, condition, relative quantity, and results can be found in the attached table for easy review and distribution.

3.2 LEAD

Lead-Based Paint (LBP): Paint or other surface coating that contains lead in excess of 1.0 milligrams per centimeter squared (mg/cm2) or 5,000 parts per million (0.7 or 600 parts per million for Los Angeles County). LBP removal and disposal must be performed in accordance with CDPH Regulations as well as California OSHA requirements.

Lead-Containing Paint (LCP): Painted material or surfaces containing lead levels between 0.1 and 1.0 mg/cm2 or 600 to 5000 ppm of lead. LCP removal and disposal must be performed in accordance with California OSHA regulations and can be handled by a regular contractor who has prepared a California OSHA lead compliance plan/program for the protection of its workers.

LCP is not a hazard to occupants per the EPA, HUD, and Cal/DPH and thus not regulated by those agencies.

Lead-Safe Paint (LSP): Painted material or surfaces containing lead levels by XRF as <0.1 mg/cm2 or <90 ppm by FAA is equivalent to the lead amount in current cans of paint sold over the counter throughout the US (approved by the Consumer Product Safety Commission).

A summary of materials sampled, condition, and results can be found in the attached table for easy review and distribution.

4 Executive Summary / Recommendations In light of Charles Taylor Environmental’s site assessment and analytical results, the following recommendations should be adhered to in order to eliminate the potential exposure of individuals to airborne asbestos fibers or lead based paint:

Proceed normally with renovations if NO Asbestos/Lead was detected.

Properly remove all ACM/ACCM or LBP/LCP that may be disturbed.

Regularly monitor ACM/ACCM or LBP/LCP that is currently in good condition.

Properly repair or remove all damaged ACM/ACCM and/or LBP/LCP.

Adhere to the following regulatory requirements.

If "any level" of asbestos is detected, Cal/OSHA still requires applicable worker protections, training, communication, notification, and engineering controls in accordance with CCR Title 8 §1529.

5 Regulatory Requirements

5.1 ASBESTOS

This survey was performed in compliance with all applicable requirements of the Asbestos Hazard Emergency Response Act (AHERA) 40 CFR 763, Cal/OSHA Asbestos Construction Standard Title 8 CCR §1529, The South Coast Air Quality Management District (SCAQMD) Rule 1403, as well as the National Emissions Standards for Hazardous Air Pollutants (NESHAP) 40 CFR 61 Subpart M.

California EPA is divided into 35 local air districts, which may have additional regulations in addition to NESHAPs. The South Coast Air Quality Management District (SCAQMD) Rule 1403 is a prominent example.

Current applicable Federal, State and Local statutes specify work practice requirements for demolition and/or renovation activities, and the associated disturbance of asbestos-containing material, as well as the storage and disposal of asbestos-containing waste material. Proper notification, removal techniques for asbestos-containing material, clean-up procedures and waste storage and disposal requirements are mandated in connection with renovation or demolition activities. Mandatory ten days or emergency asbestos removal notification is required by EPA and the South Coast Air Quality Management District (SCAQMD Rule 1403) these agencies require proper notification prior to the removal of 100 square feet and over of ACM. Other air districts, such as the Bay Area Air Quality Management District (BAAQMD), require ten-day notification prior to 100 linear or square feet of asbestos disturbance. Similarly, the Bay Area Air Quality Management District (BAAQMD Regulation 11, Rule 2) has a 100 linear and 100 square feet, and the San Diego Air Pollution Control District (SDAPCD Rule 1206) has a notification threshold of 100 square feet.

Current Occupational Safety and Health Administration (OSHA) Federal, State (Cal/OSHA) and local regulatory agencies mandated that ACM regardless of quantity shall be handled (e.g., removal, repair, etc.) by Asbestos trained and qualified individuals or Contractors. These identified ACMs should be removed by State licensed Asbestos Abatement Contractors prior to any demolition or construction activities if these ACMs would be disturbed or impacted.

Registration with Cal/OSHA is required for contractors and employers that remove asbestos having an asbestos fiber content of more than 0.1% and 100 square feet or more of surface area of asbestos-containing material. Abatement contractors must also be licensed by the California Contractors State Licensing Board (CSLB) for asbestos abatement.

Where disturbed ACM is >1% asbestos, a Procedure 5 notification to the local NESHAP enforcement authority (South Coast Air Quality Management District- SCAQMD) must be submitted along with a written scope of work and be approved prior to the start of abatement activities. Areas covered by SCAQMD include Los Angeles County, Orange County, Riverside County, and San Bernardino County.

It is Federal, State and Local agency requirements to maintain proof of compliance (asbestos handling records) and disposal of asbestos) (waste chain of custody) by owner. Asbestos responsibility and ownership are forever. An EPA/State of California certified and approved Asbestos Abatement Contractor and Hazardous Waste Hauler must perform the asbestos abatement and decontamination, and transport to a State approved landfill.

5.2 LEAD

The California Department of Public Health currently defines LBP as paint with lead levels:

• Equal to or exceeding 1.0 milligram per square centimeter (mg/cm2) or 0.5 percent (%) by weight.

However, the California Occupational Safety and Health Administration regulates paint with lead levels:

• Equal to or exceeding 0.1 mg/cm2 or 0.06 percent (%) by weight.

Lead-Based Paint (LBP): Paint or other surface coating that contains lead in excess of 1.0 milligrams per centimeter squared (mg/cm2) or 5,000 parts per million (0.7 or 600 parts per million for Los Angeles County). LBP removal and disposal must be performed in accordance with CDPH Regulations as well as California OSHA requirements.

Lead-Containing Paint (LCP): Painted material or surfaces containing lead levels between 0.1 and 1.0 mg/cm2 or 90 to 5000 ppm of lead. LCP removal and disposal must be performed in accordance with California OSHA regulations and can be handled by a regular contractor who has prepared a California OSHA lead compliance plan/program for the protection of its workers.

LCP is not a hazard to occupants per the EPA, HUD, and Cal/DPH and thus not regulated by those agencies. Lead paints below 600 ppm are unlikely to cause an overexposure if not disturbed by a trigger task, such as demolition, scraping, sanding, etc.

Lead-Safe Paint (LSP): Painted material or surfaces containing lead levels by XRF as <0.1 mg/cm2 or <90 ppm by FAA is equivalent to the lead amount in current cans of paint sold over the counter throughout the US (approved by the Consumer Product Safety Commission).

Charles Taylor Environmental highly recommends that a qualified abatement contractor perform work where lead concentration is equal to or above 600 parts per million and/or 1.0 milligram per square centimeter or where regulated levels of lead are identified.

The disposal characterization of suspect lead contaminated wastes is nuanced in California, and it starts with the Total Threshold Limit Concentration (TTLC) waste characterization test. Depending on the result of the TTLC, further Soluble Threshold Limit Concentration (STLC) and Toxicity Characteristic Leaching Procedure (TCLP) testing may be required. Therefore, it recommended to check with the laboratory on required amounts or mass of wastes to profile.

6 Limitations This survey was conducted in conformance with EPA and OSHA Guidelines. Charles Taylor Environmental utilizes established best practices and techniques in accordance with regulatory standards while performing this survey. Charles Taylor Environmental cannot be responsible for changing conditions that may alter relative exposure risk or for future changes in accepted methodology. Charles Taylor Environmental does not guarantee either expressed or implied that all asbestos/lead materials were sampled during this survey. Charles Taylor Environmental was retained only to perform the asbestos/lead survey on accessible materials within the scope of work. The findings shall only be applicable to the samples taken, the exact sample locations, at the time that the samples were collected. In some cases, hidden or indistinguishable materials may not have been sampled. Materials that were not sampled shall be presumed to be ACM/LBP. All quantities are visually estimated. The owner, operator, or abatement contractor must verify quantities prior to abatement or any financial transactions involving these materials. Finally, Charles Taylor Environmental shall not be held responsible for the deficiencies or omissions of others in relation to the services contracted herein.

7 Qualifications Individuals comprising the organization of Charles Taylor Environmental are certified by the State of California Division of Occupational Safety and Health (Cal/OSHA) as Asbestos Consultants and Site Surveillance Technicians as well as accredited by the State of California Department of Public Health Childhood Lead Poisoning Protection Branch for Lead Related Construction inspection/sampling the U.S. Department of Housing and Urban Development (HUD, and the U.S. Environmental Protection Agency (EPA). The pertinent certifications conform to the United States and California requirements that all refresher courses remain current. Note that Asbestos Consultants must maintain current accreditation as a Building Inspector, Contractor/Supervisor, Project Designer, and Management Planner. Site Surveillance Technicians must be current as a Building Inspector and Contractor/Supervisor.

Any individual performing services as an asbestos consultant or site surveillance technician as referenced and defined in §1529(b) of Title 8 of the California Code of Regulations must apply for and obtain a certification pursuant to this article. This does not apply to individuals who perform preliminary site assessments or other such building inspection activities which may identify asbestos-containing construction materials, but which are not for the primary purpose of finding asbestos-containing construction materials in buildings and evaluating the materials for the need of asbestos abatement. (Title 8 CCR §1529 and § 341.15).

"Asbestos consultant" means any person who contracts to provide professional health and safety services relating to asbestos-containing construction material as defined in this subsection, which comprises 100 square feet or more of surface area. The activities of an asbestos consultant include building inspection, abatement project design, contract administration, sample collection, preparation of asbestos management plans, clearance monitoring, and supervision of site surveillance technicians as defined within §7180, Business and Professions Code; and Sections 60.5, 6308, and 9021.5, Labor Code. Reference:

Sections 7184 and 7185, Business and Professions Code; Sections 9021.5, 9021.6, and 9021.8, Labor Code; and Section 1529, Title 8, California Code of Regulations.

“Certified lead inspector/assessor” means an individual who has received a certificate or an interim certificate from the Department as a “certified lead inspector/assessor”. Note: Authority cited: Sections 105250, 124160 and 131200, Health and Safety Code. Reference: Sections 105250, 124160 and 131051, Health and Safety Code.

“Certified lead sampling technician” means an individual who has received a certificate or an interim certificate from the Department as a “certified lead sampling technician”. Note:

Authority cited: Sections 105250, 124160 and 131200, Health and Safety Code. Reference:

Sections 105250, 124160 and 131051, Health and Safety Code.

Signature and Consultant Certification

Stephanie Davis Report prepared by:

Kyle Gamez Inspector Name CSST Certification # 10-4616 CDPH Certification # LRC-0003113

Michael Nave Senior Reviewer Name Certified Asbestos Consultant # 07-4253 CDPH Certification # LRC-00002907, 2906

Attachments:

Results Summary Tables Laboratory Results Chain-of-Custody Site Diagram CDPH 8552 Form Consultants/Technicians Certification

2556 W Woodland Dr Anaheim, CA 92801

BULK ASBESTOS FIBER ANALYSIS

BY POLARIZED LIGHT MICROSCOPY

Phone:(562) 860-2201 www.aihlab.com

Client Name:

Charles Taylor Environmental Technical Services

Project Manager: Kyle Gamez

Client Address: 301 Merritt 7, 2nd Floor, Norwalk, CT 06851

Project Number: 2128393

Project Location:

451 East Vanderbilt Way, San Bernardino, CA 92408

Lab Batch Number: 2507672

Samples Submitted: 4

Samples Analyzed: 4

Analysis Method: EPA 600/R-93-116 &

EPA 600/M4-82-020

Lab Notes at Page 2 V14-1A Page 1 of 2

Lab ID: 250767201 Client ID: A1

Layer Layer Description Asbestos Type % Other Fibrous Material % Other Non Fibrous

Material

1. White compacted powdery material with paint None Detected None Detected JC/Binder, Paint

2. Textured paint None Detected None Detected Binder/Filler, Paint

3. White chalky material with paper None Detected Cellulose 6% Gypsum/Binder

Lab ID: 250767202 Client ID: A2

Layer Layer Description Asbestos Type % Other Fibrous Material % Other Non Fibrous

Material

1. White compacted powdery material with paint None Detected None Detected Binder/Filler, Paint

2. White compacted powdery material with paper None Detected Cellulose 2% JC/Binder

3. White chalky material with paper None Detected Cellulose 6% Gypsum/Binder

Lab ID: 250767203 Client ID: A3

Layer Layer Description Asbestos Type % Other Fibrous Material % Other Non Fibrous

Material

1. White compacted powdery material with paint None Detected None Detected Binder/Filler, Paint

2. White compacted powdery material with paper None Detected Cellulose 2% JC/Binder

3. White chalky material with paper None Detected Cellulose 6% Gypsum/Binder

Lab ID: 250767204 Client ID: A4

Layer Layer Description Asbestos Type % Other Fibrous Material % Other Non Fibrous

Material

1. White compacted powdery material with paint None Detected None Detected JC/Binder, Paint

2. White chalky material with paper None Detected Cellulose 6% Gypsum/Binder

2556 W Woodland Dr Anaheim, CA 92801

BULK ASBESTOS FIBER ANALYSIS

BY POLARIZED LIGHT MICROSCOPY

Phone:(562) 860-2201 www.aihlab.com

Client Name:

Charles Taylor Environmental Technical Services

Project Manager: Kyle Gamez

Client Address: 301 Merritt 7, 2nd Floor, Norwalk, CT 06851

Project Number: 2128393

Project Location:

451 East Vanderbilt Way, San Bernardino, CA 92408

Lab Batch Number: 2507672

Samples Submitted: 4

Samples Analyzed: 4

Analysis Method: EPA 600/R-93-116 &

EPA 600/M4-82-020

Lab Notes at Page 2 V14-1A Page 2 of 2

Analyzed by:

Hanaa Armanious

Signature: Date: 04-10-2025

Reviewed by: Zubair Ahmed Signature: Date: 04-10-2025

*Total Layers Analyzed:11

Reporting limit is 1%. If the sample was not collected by AIH Laboratory then the accuracy of the results is limited by the methodology and experience of the sample collector. Clients can verify specific reporting limit requirement from local regulatory agencies. Liability limited to cost of samples analysis. This report shall not be reproduced except in full, without written approval of AIH Laboratory. It shall not be used to claim product endorsement by NVLAP or any other agency of the government. Reported results relate only to the samples tested and may not be the representative of the sample area. AIH Laboratory shall dispose of the Customer's samples 14 days after receiving the samples unless instructed to store them for an alternate period of time in writing.