Asbestos___Lead_Rpt_-_Cow_Creek__Bldg__CC-50.pdf

ASBESTOS SURVEY &

LEAD-BASED PAINT

INSPECTION REPORT

COW CREEK MAINTENANCE FACILITIES

BUILDING CC-50

DEATH VALLEY NATIONAL PARK, CALIFORNIA

December 19, 2019

PREPARED FOR:

Mr. David Norman Provost and Pritchard Consulting Group

2505 Alluvial Avenue Clovis, California 93611

PREPARED BY:

T. BROOKS & ASSOCIATES, INC.

613 Harvard Avenue, Suite 201 Clovis, California 93612

(559) 298-9135

(559) 298-2281 - Fax

Formed 1993

Troy F. Brooks, RRC, CAC, CIEC Registered Roof Consultant

Certified Asbestos Consultant, #92-0186 DPH Inspector/Assessor for Lead, #1398

Certified Indoor Environmental Consultant

Roof Consulting / Asbestos, Lead & IAQ Consulting

T. Brooks & Associates, Inc.

December 19, 2019 Project #19-9169

Mr. David Norman Provost and Pritchard Consulting Group 2505 Alluvial Avenue Clovis, California 93611

SUBJECT: Asbestos Survey & Lead-Based Paint Inspection Report Cow Creek Maintenance Facilities– Bldg. CC-50 Death Valley National Park Death Valley, California

Dear Mr. Norman:

In accordance with your request and authorization, T. Brooks & Associates, Inc. conducted an Asbestos Survey and Lead-Based Paint Inspection involving the above referenced historic structure located in Death Valley National Park in Death Valley, California and has prepared the enclosed asbestos and lead report based on that investigation. The survey was requested due to planned renovation/demolition operations involving the referenced structure considered as part of our investigation.

The Client wishes to be notified as to the presence of asbestos-containing materials and/or lead-based or lead-containing paint which may impact proposed renovation/demolition operations involving the subject structure.

We appreciate the opportunity to assist you. If you should have questions or require additional information, please contact us at (559) 298-9135.

Respectfully, T. BROOKS & ASSOCIATES, INC.

Troy F. Brooks, CAC, RRC, CIEC Certified Asbestos Consultant, No. 92-0186 CDPH Inspector/Assessor for Lead, No. 1398 Registered Roof Consultant, R.C.I., Inc.

TABLE OF CONTENTS

Page

INTRODUCTION.…………………………………………………………………………………

ASBESTOS INVESTIGATION…….…………………………………...…………………….…

OBJECTIVE AND SCOPE OF SERVICES- ASBESTOS …..……………………………………1

APPLICABLE REGULATIONS FOR ASBESTOS……………………….………………………..1

INVESTIGATION ….………………………………………………………...………………………..3

ANALYSIS OF FINDINGS - ASBESTOS ..……………………………………………………..….4

ADDITIONAL CONSIDERATIONS - ASBESTOS………………………………………...……

REGULATORY AGENCIES AND REQUIREMENTS …………………………...………………5

RECOMMENDATIONS- ASBESTOS……..…...……………………..………………………..…..5

LEAD INVESTIGATION……………..…………………………….……………………….……

OBJECTIVE AND SCOPE OF SERVICES - LEAD …………………. ……………..………

SAMPLE METHODOLOGY……………………………………………………………..………..….7

SAMPLING EQUIPMENT.……..………………………………………………………..………..….7

APPLICABLE REGULATIONS FOR LEAD …………………………...………..……………...….7

ANALYSIS OF FINDINGS - LEAD………………………………….………………………....…..10

PAINT CONDITION …………...…...………………………………. …….……………………

ADDITIONAL CONSIDERATIONS - LEAD .……...……………… …….……………….…..….12

RECOMMENDATIONS- LEAD ……..……………...………………. ….…………………………12

LIMITATIONS………………………...………………..…………….…….………………………...13

SAMPLED MATERIALS ANALYTICAL RESULTS - ASBESTOS TABLE 1

ASBESTOS-CONTAINING MATERIALS ASSESSMENT TABLE 2

APPENDICES

Appendix A - Laboratory Report for Asbestos & Chain of Custody (PLM analysis) Appendix B - Site Plan Indicating Asbestos Sampling Locations & Lead Sampling Orientation Appendix C - XRF Results for Lead Appendix D - XRF Results for Lead – Positive Reading in Excess of 1.0 mg/cm² Appendix E - Calibration Check Test Results Appendix F - Great Basin Unified Air Pollution Control District Forms & Fee Schedule Appendix G - Regulatory Resource List – Asbestos & Lead Appendix H - Certifications Professional & Laboratory Certifications

ASBESTOS SURVEY &

LEAD-BASED PAINT INSPECTION REPORT

COW CREEK MAINTENANCE FACILITIES

BUILDING CC-50

DEATH VALLEY NATIONAL PARK

DEATH VALLEY, CALIFORNIA

INTRODUCTION

In accordance with your request and authorization, T. Brooks & Associates, Inc. has conducted an Asbestos Survey and Lead-Based Paint Inspection involving the above referenced structure located in Death Valley National Park, California to be impacted as part of the referenced project. It is our understanding that the survey was requested in order to identify the presence and locations of asbestos-containing material, “lead-based paint’ and “lead-containing paint’ involving the subject historic structure considered as part of our investigation. The following sections present a description of the structure, current site use, pertinent regulatory information, and description of sampled materials, analysis of findings, and our recommendations specific to compliance with renovation operations.

ASBESTOS INVESTIGATION

OBJECTIVE AND SCOPE OF SERVICES - ASBESTOS

The objective of this investigation was to evaluate existing suspect building materials as to asbestos content in accordance with applicable regulations. This investigation consisted of limited, representative bulk sampling, and subsequent laboratory analysis of suspect building materials at specified interior and exterior locations of the subject structure considered as part of our investigation.

Sampling was conducted utilizing limited destructive techniques. Suspect asbestos-containing materials were characterized by size, color and texture in order to quantify materials and to draw conclusions based on bulk sample results.

Bulk sample analysis was provided by EMC Laboratories, an independent, accredited laboratory specializing in asbestos analysis. Bulk samples were individually bagged and numbered for identification and to maintain a chain-of-custody as part of this report.

APPLICABLE REGULATIONS

Occupational Safety and Health Administration

The Occupational Safety and Health Administration (OSHA), regulates construction activities including those which involve asbestos containing materials. OSHA regulations for asbestos materials

Asbestos Survey & Lead-Based Paint Inspection Report Project #19-9169 Cow Creek Maintenance Facilities– Bldg. CC-50, Death Valley National Park, CA Page 2 of 14 exist at both state (Cal-OSHA) and federal (Fed-OSHA) levels and are intended to protect workers from occupational exposures to these materials.

Federal asbestos regulations, including the Federal OSHA Construction Industry Asbestos

Standard (29 CFR 1926.1101) and State of California OSHA Standard (Title 8 CCR 1529) mandate that all construction materials classified as Thermal System Insulation (TSI), or Surfacing Material

(sprayed or troweled in place and of an acoustical nature) installed in buildings prior to January 1, 1981, be classified as “Presumed Asbestos Containing Materials”(PACM). This designation may only be refuted by extensive testing procedures of each homogeneous material in compliance with 40 CFR

763 Subpart E, the AHERA regulations of the EPA).

Appropriate controls including air sampling are required during the removal of any asbestos-containing material (ACM) in order to document fiber release, which may expose workers or others to hazardous levels of airborne asbestos.

Certified Asbestos Consultant and Site Surveillance Technician

The California Business and Professions Code specifies that only a State of California, Certified Asbestos Consultant may provide design, environmental air sampling and other consulting services on behalf of building owners relating to abatement projects. Certified Site Surveillance

Technicians typically perform bulk sampling, air monitoring, and other functions under the surveillance of a Certified Asbestos Consultant.

Definition of Asbestos-Containing Material

Cal-OSHA >0.1% by weight * State of California, Health & Safety Code >0.1% Fed-OSHA >1.0% by weight Cal-EPA friable and >1.0% asbestos EPA friable and >1.0% asbestos

* Under Cal-OSHA regulations, building materials containing between 0.01%-1.0% are classified as

Asbestos-Containing Construction Material (ACCM). The material is not regulated by the EPA and waste may be disposed of as non-hazardous. Cal-OSHA regulations would be applicable for worker protection.

Work Categories - Fed OSHA, 29 CFR 1926.1101 Cal-OSHA, Title 8, CCR 1529

Classify abatement operations under four distinct activities, which trigger different provisions within the standard. Those activities presenting the greatest risk are designated Class I work, with decreasing risk potential for each successive class.

Cow Creek Maintenance Facilities– Bldg. CC-50, Death Valley National Park, CA Page 3 of 14

The work categories and brief descriptions are as follows:

Class I - Abatement involving thermal system insulation (TSI) and sprayed-on or troweled-on or otherwise applied surfacing ACM.

Class II - Abatement of ACM or PACM other than TSI or Surfacing Materials.

Class III - Repair and maintenance operations which are likely to disturb ACM, or

PACM.

Class IV - Custodial and housekeeping operations where minimal contact with ACM and/or PACM may occur.

Unclassified - Operations involving abatement of materials which contain detectable levels of asbestos up to and including, but not in excess of 1%.

Refer to Appendix G for additional information regarding specific procedures for demolition activities involving targeted facilities.

INVESTIGATION

The inspection and sampling event was conducted by Troy Brooks, Certified Asbestos

Consultant, No. 92-0186, on December 10, 2019. Professional Certifications and Laboratory

Certifications are presented in Appendix H.

Building Construction and Use

The subject site location consists of a historic structure. The structure is of adobe construction with supporting wood framing. Interior walls consist of gypsum wallboard. The structure includes a suspended ceiling system. Flooring finishes consist of sheet vinyl and wood flooring. The age of the structure was not provided for our use. A floor plan was prepared for our use in documenting sampling locations and quantifying any materials testing positive for asbestos content.

Materials Sampled

Representative samples were collected at specified interior and exterior locations at the subject site considered as part of our investigation. Materials to be sampled were at the discretion of the sampler and were selected based upon the likelihood of containing asbestos as an integral or incidental part of their construction.

Cow Creek Maintenance Facilities– Bldg. CC-50, Death Valley National Park, CA Page 4 of 14

Materials selected for sampling and subsequent laboratory analysis included the following:

LOCATION: Cow Creek Maintenance Facilities – Building CC-50, Death Valley National Park, CA

Sampled Materials EPA Classification NESHAP CAT.*

Ceiling Materials

- 2’x2’ Ceiling Tile Miscellaneous Material RACM

Wall Materials

- Adobe Wall Miscellaneous Material RACM

- Drywall w/ Taping Mud & Texture Miscellaneous Material RACM

- Drywall Taping Mud w/ Texture Miscellaneous Material RACM

Flooring Materials

- Vinyl Sheet Flooring w/ Mastic Miscellaneous Material RACM

- Vinyl Sheet Flooring Miscellaneous Material RACM

Miscellaneous Materials

- Window Caulking Miscellaneous Material Cat. II, N.F.

- Roof Underlayment Miscellaneous Material Cat. I, N.F.

* These classifications are based on classifications by the AHERA regulations of the Environmental Protection Agency. All asbestos-containing materials may be rendered friable by the forces acting upon them.

Sample Results Of those samples submitted for analysis, none (0) tested positive for asbestos. Based on the laboratory findings, those building materials testing negative for asbestos may be treated as negative for the purposes of planned renovation/demolition operations involving those portions of the subject structure considered as part of our investigation.

ANALYSIS OF FINDINGS

Asbestos-containing materials are classified by their "Friability" which is defined as material that when dry may be crumbled, pulverized, or reduced to powder by hand pressure. In addition, the

"Friability" classification is not only determined by the nature and condition of the ACM, but also by work practices to which the material may be exposed during renovation or demolition activities. The

"Friability" classification is critical in determining the applicable regulations, work practices and disposal requirements.

ADDITIONAL CONSIDERATIONS

Fees to the SJVAPCD would be required for abatement and/or renovation work which includes disturbance of more than 160 s.f., of “Regulated Asbestos-Containing Materials” (RACM), or non-friable ACM which is rendered friable.

Cow Creek Maintenance Facilities– Bldg. CC-50, Death Valley National Park, CA Page 5 of 14

Proposed abatement and renovation operations require compliance with Cal/OSHA and

NESHAP regulations and procedures. A mandatory ten (10) working day waiting period is required prior to proceeding with regulated abatement, defined as disturbance of threshold amount of RACM, or non-friable ACM which becomes friable if the total amount of RACM is equal to or in excess of 100 square feet. In addition, non-friable ACM which becomes friable would be included in the total under the requirements. Any demolition is defined under the NESHAP would be regulated regardless of whether asbestos is present which will be disturbed.

REGULATORY AGENCIES AND REQUIREMENTS

Following is a brief description of regulatory agencies and regulatory requirements:

Federal

Environmental Protection Agency (EPA) - NESHAP Notification - 04 CFR 16 - Subpart M

Requires notification in all “demolition” operations, whether the building contains asbestos or not. Requires notification when renovation/demolition involves greater than 160 square feet or 260 linear feet of friable ACM.

Great Basin Unified Air Pollution Control District

Great Basin Unified Air Pollution Control District (GBUAPCD) - Enforcement of NESHAP regulations.

Enforces notification for all “demolition” operations whether the building contains asbestos or not, and all renovation project involving in excess of 160 square feet, 260 linear feet, or 35 cubic feet of RACM. Requires the removal of all regulated quantities of RACM before demolition/renovation process. Non-friable (Category I and II) ACM may be required to be removed at the discretion of the local air pollution control district.

Cal-OSHA

State of California, Department of Industrial Relations, Division of Occupational Safety and Health Enforces regulations pertaining to worker protection. New Cal-OSHA standard (8 CCR 1529 (took effect on July 1, 1991) and was adopted from the Federal OSHA standard. The standard mandates procedures and engineering controls necessary to protect employees of the contractor, building occupants and others. Requires filing of a “Temporary Jobsite Notification” with the local compliance office prior to commencing with abatement activities involving any quantity of material.

RECOMMENDATIONS

Prior to proceeding with any operation classified as a “Demolition” under the NESHAP and

Great Basin Unified Air Pollution Control District, comply with the Notification requirements of the

GBUAPCD and pay fees (if required). Wait the required ten (10) working-days after filing the notification before proceeding with regulated demolition activities. A “demolition” is defined as removal

Cow Creek Maintenance Facilities– Bldg. CC-50, Death Valley National Park, CA Page 6 of 14 of any load-bearing member, regardless of the fact that no asbestos-containing building materials are present which will be disturbed.

LEAD-BASED PAINT INSPECTION REPORT

OBJECTIVE AND SCOPE OF SERVICES – LEAD

The inspection and lead sampling event of the subject structure was conducted by Troy

Brooks, Inspector/Assessor for Lead, No. 193. Professional Certifications and Laboratory

Certifications are presented in Appendix H.

Scope of Investigation The Lead-Based Paint Inspection was conducted in accordance with Title 17 - California Code of Regulations, Division 1, Chapter 8, and 8 CCR 1532.1 (Cal/OSHA). The sampling event was conducted in a manner which provides limited, representative evaluation of painted surfaces at referenced locations at the subject site in accordance with the HUD schedule in Chapter 7 (Lead-

Based Paint Inspection) of the “Guidelines for the Evaluation and Control of Lead-Based Paint

Hazards in Housing”. Testing locations provide an overall representation of painted finishes present at the site. The referenced inspection is representative in nature and is limited based on the limitations of the referenced regulatory standard.

The sampling methodology includes testing of painted finishes affixed to the subject structure based on a four-sided configuration (Sides A – D). As such, one (1) representative painted component affixed to the subject structure is typically tested at each side of the structure or individual room under consideration. The tested component is intended to be representative of all matching components on the referenced side, although not all matching components are tested. Refer to Appendix B for information concerning the Lead Sampling Orientation of the structure.

Sampling of painted surfaces for suspect lead-based paint at the specified structure included testing of eighty-eight (88) separate testing combinations. The XRF instrument was calibrated prior to and following the prescribed sampling periods in accordance with the Performance Characteristic

Sheet provided by the manufacturer. Calibration readings are included in the XRF sampling results as the initial and concluding readings and are designated as a “calibrate” reading. The calibration readings were compared to a known concentration of lead using a standard SRM sheet provided by the XRF manufacturer to verify accurate performance of the instrument at the beginning and the conclusion of the sampling episode.

Cow Creek Maintenance Facilities– Bldg. CC-50, Death Valley National Park, CA Page 7 of 14

SAMPLE METHODOLOGY

Enclosed results are based on total lead content regardless of the number of paint layers present at each specific test location. Each referenced area includes data generated by the testing instrument. Lead content at a level equivalent to 5,000 ppm would be classified as “Lead-Based Paint” by HUD, The State of California, and the EPA. Each result must also be compared to the applicable

OSHA level (“any detectable amount”, or 600 ppm), dependent upon the appropriate trigger activity.

SAMPLING EQUIPMENT

Sampling was conducted using a Heuresis Spectrum Analyzer Lead Detector, Model Pb200I

Alpha (Serial No. 1029). The instrument was utilized within the operating parameters established by

Heuresis Corporation as indicated in the Performance Characteristic Sheet.

Definition of Lead-Based Paint

Title X >1.0 mg/cm² or >0.5% by weight HUD 1.0 mg/cm² or 0.5% by weight CDPH 1.0 mg/cm² or > 0.5 % by weight CPSC 600 ppm or .06% by weight OSHA 600 ppm or .06% by weight or any detectable amount

(Note subtle differences dependent upon preceding mathematical symbols)

APPLICABLE REGULATIONS FOR LEAD

The following includes the primary agencies which govern lead related work and a brief list of their components and responsibilities.

Occupational Safety and Health Administration

Federal Standards General Industry Standard 29 CFR 1910.1025

Construction Industry Standard 29 CFR Part 1926.62

State Standards General Industry Standards 8 CCR 5216

Construction Industry Standards 8 CCR 1532.1

The Occupational Safety and Health Administration (OSHA), is focused on protecting the health and safety of workers, including construction activities which disturb lead containing paints, surface coatings, and other materials. OSHA regulations for lead materials exist at both state (Cal-

OSHA) and federal (Fed-OSHA) levels and are intended to protect workers from occupational exposures to these materials.

Cow Creek Maintenance Facilities– Bldg. CC-50, Death Valley National Park, CA Page 8 of 14

Federal and State lead regulations, including the Lead in Construction Standard 29 CFR

1926.62 (Federal Standard) and Title 8 CCR 1532.1, (California standard) regulate disturbance of lead containing materials during construction, demolition, and maintenance related activities. The

Federal standard was adopted in May of 1993. The State of California adopted this standard in

November 1993.

Appropriate engineering controls, personal protective equipment, training, specific work practices, and representative air sampling are required by both Cal/OSHA and OSHA whenever workers will disturb lead in any concentration (including less than 600 ppm) as this disturbance may result in airborne exposures over the Action Limit (AL) or Permissible Exposure Limit (PEL). Initial blood lead testing is required above the AL (30 ug/m;), and a written site specific “Compliance Plan” is required for all projects where a Negative Exposure Assessment has not been generated. Medical removal is required for any worker whose blood lead level > 50 ug/dl.

U.S. Environmental Protection Agency

Title X was promulgated by the U.S. Congress in 1992 and required the U.S. Environmental

Protection Agency (USEPA), to define lead hazards and to develop certification programs.

Major components of EPA pertaining to Lead Containing Materials:

• Established a lab accreditation program

• Defined hazards in dust and soil (revised June 1998)

• Evaluates inspection & removal products (ongoing)

• Requires disclosure & information prior to sale/rental of pre-1978 housing (in effect)

• Mandate information for renovation /remodel work (in effect 6/99)

• Developed an accreditation and training program effective in states that do not have their own program California Environmental Protection Agency

Cal-EPA determines when lead paint waste is a hazardous waste in California, and how it must be disposed. The California Department of Toxic Substance Control (DTSC), as part of Cal-EPA oversees regulated disposal issues related to hazardous waste in California.

Procedures for the identification, management, transport, record keeping, and disposal of all types of hazardous waste are set forth in Title 22, CCR, Sections 66260.1-66263.12 and 66268.1-

66268.124, and the Health and Safety Code, section 25163, subdivision (c).

Department of Housing and Urban Development (HUD)

Developed regulations and guidance documents for use on HUD properties. Its Guidelines are generally considered state-of-the-art in the lead abatement industry. HUD guidelines establish

Cow Creek Maintenance Facilities– Bldg. CC-50, Death Valley National Park, CA Page 9 of 14 strategies for completion of lead survey and risk assessments, clearance strategies, work practices, engineering controls and worker safety procedures.

While HUD guidance documents were developed specifically for HUD properties, both the

California DPH work practice regulations and the EPA Model Accreditation Program for lead mandate you follow HUD Guideline procedures in many facilities.

HUD developed the following guidance documents which are industry standards:

• 1989 - published A Lead-based Paint: Interim Guidelines for Hazard Identification and

Abatement in Public and Indian Housing, referred to as the “Old HUD Guidelines”.

• 1995 - published “Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing”.

California Department of Public Health (CDPH) Developed and enforces a comprehensive regulation that provides an accreditation process for lead training providers, a certification program for individuals, and specified required work practices for lead hazard evaluations and lead hazard control work.

• Promulgated the California CDPH Lead Training, Accreditation, Certification and Work

Practices - Title 17, CCR, Division 1, Chapter 8, (Sections 35000-361000). Specifies work practices involved in lead inspections, risk assessments and hazard reduction work in all residential and public buildings in California. Also requires training, passage of exams, and certification of individuals that conduct lead hazard assessments or work to reduce or eliminate lead hazards. Revised standard took effect on January 8, 1999.

Key Provisions: Defines “lead hazards” in dust, paint, and soil

Defines almost all paint as “presumed” LBP Excludes post 1978 housing, and schools built after 1992 Requires notifications to CDPH prior to disturbance of LBP Requires specific work practices (containment, clearance testing, etc.)

Requires individuals to be “certified” for some work

CDPH Certification is required in the following cases:

• Exceed PEL in California (50 ug/m³) (Cal-OSHA)

• Conduct lead hazard evaluation or “abatement” (CDPH)

• Residential Inspections for EPA Disclosure Rule compliance

• Title X funded projects (U.S. Congress)

• California public elementary and preschools (Ed. Code Section 32243 b)

• When prescribed by project specifications.

Cow Creek Maintenance Facilities– Bldg. CC-50, Death Valley National Park, CA Page 10 of 14

CDPH Certification Classifications Brief Description

Lead Related Inspector/Assessor Conduct inspections or assessments for LBP Lead Related Supervisor Supervise lead project as Contractor Lead Related Project Monitor Monitor lead project on behalf of Client Lead Related Project Designer Design a lead abatement project Lead Related Worker Engage is lead related work as a worker

OSHA Trigger Activities (Tasks):

Fed OSHA, 29 CFR 1926.62 Cal-OSHA, Title 8, CCR 1532.1

Classify trigger tasks under three distinct activity groups which assume that you may reach specified airborne exposure levels. Those tasks presenting the least risk are designated Activity 1 tasks, with increasing risk potential for each successive class.

The three (3) trigger task categories and assumed airborne levels are as follows:

Trigger Activity I - (50 -500 ug/m³) manual demolition, scraping and sanding, using heat guns, using HEPA equipment, debris cleanup

Trigger Activity II - (500 - 2500 ug/m³) lead mortar, burning, rivet busting, use of non-HEPA equipment, dry abrasive blast cleanup

Trigger Activity III - (>2500 ug/m³) welding, abrasive blasting, torch cutting, and burning

Prior to obtaining exposure assessment for each specific trigger task or if no historic data is available, the following apply:

• assume exposure over “PEL”

• wear respirators and protective clothing

• be properly trained per state and federal requirements

• have initial blood tests on affected workers, supervisors

Refer to Appendix G – “Regulatory Resource List” for specific information regarding trigger task activities and specific requirements.

ANALYSIS OF FINDINGS – LEAD

Certain of the testing combinations considered as part of our limited investigation were found to contain lead in some amount. Under current Cal/OSHA regulations, paint containing in excess of

0.06% lead (600 parts per million) are considered lead-containing paint for non-trigger tasks under

Cow Creek Maintenance Facilities– Bldg. CC-50, Death Valley National Park, CA Page 11 of 14

Cal/OSHA. For trigger tasks, any detectable amount of lead invokes Cal/OSHA regulations and assumes that airborne levels may exceed the “Action Level” (AL) of 30 ug/m³, and the “Permissible

Exposure Limit” (PEL) of 50 ug/m³. Refer to Appendix G for additional information concerning regulatory requirements.

Current OSHA regulations require that workers involved in work disturbing lead containing surfaces be protected from exposure to lead above stipulated levels. Refer to the enclosed OSHA

Construction Standard (CCR Title 8 1532.1 California Lead-In-Construction Standard) for work guidelines and requirements.

Of those testing combinations considered as part of our investigation, a total of ten (10) were found to include lead in excess of the 1.0 mg/cm², (0.5%), (5,000 ppm) and would be classified as

“Lead-Based Paint” (LBP) under state and federal regulations. Each of the Testing Combinations found to include lead in amounts classified as ‘Lead Based Paint” was at exterior building locations.

Refer to Appendices B-D for additional information concerning specific Testing Combinations.

Building materials represented by those testing combinations found to include lead in excess of 1.0 mg/cm², (0.5%), (5,000 ppm) are classified as “Lead-Based Paint” (LBP) for the purposes of compliance with state and federal regulations. In addition, Cal/OSHA regulates all activities involving the disturbance of paint which includes “any detectable” amount of lead.

Any construction related work which will disturb building elements which include paint or surface coatings determined to include lead must be conducted in accordance with applicable local, state and federal regulations governing disturbance of lead. A lead waste characterization is required under state and federal requirements prior to disposing of lead-containing waste.

Refer to Appendices B-D for additional information concerning specific testing combinations.

Any construction related work which will disturb building elements which include paint or surface coatings determined to include “Lead-Based Paint” must be conducted in accordance with applicable local, state and federal regulations governing disturbance of lead. A lead waste characterization is required prior to disposing of ceramic tile, or the material must be disposed of as lead-containing waste.

PAINT CONDITION

As part of the Lead-Based Paint Inspection, painted surfaces were visually examined for general condition. While this report does not constitute a lead “Risk Assessment”, painted surfaces were generally categorized as being in intact, fair, poor, or peeling condition.

Cow Creek Maintenance Facilities– Bldg. CC-50, Death Valley National Park, CA Page 12 of 14

Each of the testing combinations found to include lead in an amount classified as “Lead-Based

Paint” was found to be in “Intact” condition at the time of the investigation. Painted finishes classified as “Lead-Based Paint” and determined to be in “Intact” condition are NOT classified by the California, Department of Public Health and the EPA as a “Lead Hazard”.

ADDITIONAL CONSIDERATIONS

Hazards associated with lead exposure are typically due to ingestion and inhalation of lead in the form of dust. Lead can be determined within the bloodstream, bones, and other organs by various detection methods.

Potential exposure to lead is associated with damaged painted surfaces. Painted surfaces should be inspected regularly and maintained in intact, undamaged condition to minimize the potential for the creation of lead dust hazards. Any evidence of peeling, lose or detached paint should be rectified by stabilizing the painted surface or replacing the painted element.

RECOMMENDATIONS

All future construction-related work which includes the disturbance of “Lead-Based Paint” or

“Lead-Containing Paint” must be conducted in compliance with Cal/OSHA and State of California requirements. Prior to engaging in work which will disturb lead finishes referenced herein, or other untested paints or surface coatings, the contractor engaged in the work must conduct an “Initial

Exposure Assessment” for each planned “trigger task” in accordance with Cal/OSHA to determine potential lead exposures to workers. Prior to commencing such operations, the Contractor must assume workers will be exposed to airborne levels above the PEL and must provide workers with

Hazard Communication Training, and personal protective equipment, including HEPA-equipped respirators. A hand-washing facility must be present at the worksite. Refer to Appendix G for information concerning regulatory requirements.

Planned work operations involving disturbance of lead must be conducted in accordance with

Cal/OSHA regulations. A barrier system must be in place and water applied for dust suppression during the work operations.

Prior to Disposal of lead-containing paint or elements which include lead-containing paint, the

State of California requires that representative sample(s) of the waste stream waste (along with the substrate where bonded) be submitted to an accredited laboratory and that a Total Threshold Limit

Concentration (TTLC) test be performed to determine the total lead content. Dependent upon the result, a SW846 (STLC) may be required to determine the amount of leachable lead. These tests will

Cow Creek Maintenance Facilities– Bldg. CC-50, Death Valley National Park, CA Page 13 of 14 determine transportation and disposal requirements and may greatly impact the ultimate cost of the work. Due to potential delays associated with conducting the analysis of the waste, it is recommended that the waste characterization be initiated prior to soliciting for bids for the work.

LIMITATIONS

This investigation is undertaken with the calculated risk that the presence, full nature, and extent of asbestos and lead-containing materials would not be revealed by visual observation and random sampling alone. T. Brooks & Associates, Inc. makes no representations as to the asbestos or lead content of materials which were not specifically tested or which were not readily accessible to the inspector. The enclosed findings and recommendations are not intended to represent materials at locations other than those specifically referenced.

Brooks & Associates is not responsible for failure of the Client and/or other design professionals or contractors working under their direction to completely review the enclosed report, and to thoroughly research regulatory requirements related to those building materials and finishes to be impacted by their work.

Certain opinions and recommendations expressed in this report are based on our knowledge and experience with applicable state, federal and local law, and do not reflect other possible adverse conditions not immediately visible or which may be discovered by a more extensive examination including a review of relevant documents which were not available during this investigation.

Our inspection did not include sampling of materials which may contain materials known to be hazardous including polychlorinated biphenyls (PCB’s), mercury, radon or other materials.

Consideration should be given to testing for these and other hazardous materials which may be present.

Findings presented in this report were based on field observations, random sampling and analysis, review of available data and discussion with local regulatory and advisory agencies.

Therefore, the data obtained are clear and accurate only to the degree implied by the sources and methods involved.

The information presented herewith was based on professional interpretation using presently accepted methods with a degree of conservation deemed proper as of the report date. It is not warranted that such data and/or methods cannot be superseded by future technical developments.

Cow Creek Maintenance Facilities– Bldg. CC-50, Death Valley National Park, CA Page 14 of 14

Respectfully Submitted, T. Brooks & Associates, Inc., Troy F. Brooks, CAC, RRC, CIEC, CDPH Certified Asbestos Consultant, No. 92-0186 CDPH Inspector/Assessor for Lead, No. 1398

End of Report

Asbestos Survey and Lead-Based Paint Inspection Report Cow Creek Maintenance Facilities - Building CC-50, Death Valley National Park Project No. 19-9169

TABLE 1

SAMPLED MATERIALS ANALYTICAL RESULTS

Client Layer Material Sample Analytical ID Description Location Results

1-01 1 Adobe Wall Exterior - Wall None Detected

1-02 1 Adobe Wall Exterior - Wall None Detected

2-01 1 2' x 2' Ceiling Tile Room 1 - Ceiling None Detected

2-02 1 2' x 2' Ceiling Tile Room 2 - Ceiling None Detected

3-01 1-3 Drywall, Taping Mud & Texture Room 3 - Wall None Detected

3-02 1-3 Drywall, Taping Mud & Texture Room 1 - Wall None Detected

3-03 1-3 Drywall, Taping Mud & Texture Room 5 - Wall None Detected

3-04 1-3 Drywall, Taping Mud & Texture Room 2 - Wall None Detected

3-05 1-2 Taping Mud & Texture Room 4 - Wall None Detected

4-01 1-2 Vinyl Sheet Flooring & Mastic Room 1 - Floor None Detected

4-02 1 Vinyl Sheet Flooring Room 2 - Floor None Detected

5-01 1 Window Caulking Exterior None Detected

5-02 1 Window Caulking Exterior None Detected

6-01 1 Roof Underlayment Roof None Detected

6-02 1 Roof Underlayment Roof None Detected

Cow Creek Maintenance Facilities

Death Valley National Park Death Valley, California

Building CC-50

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