Attachment 12 - Citadel Environmental Services Inc Limited Lead (XRF) Survey 2013 - 1 of 6.pdf

December 27, 2013

Chae Kim Contracting Officer Representative/Asbestos Manager

DEPARTMENT OF VETERANS AFFAIRS SAN DIEGO HEALTHCARE SYSTEM

3350 La Jolla Village Drive San Diego, California 92161

Re: CITADEL Project No. 5137.1148.0 Limited Lead (XRF) Survey Report Department of Veterans Affairs San Diego Healthcare System VA Medical Center - Building 1 3350 La Jolla Village Drive San Diego, California 92161

Dear Mr. Kim:

Enclosed please find Citadel Environmental Services, Inc.'s Limited Lead (XRF) Survey Report for the above-referenced location.

The limited XRF survey was conducted for the Department of Veterans Affairs San Diego Healthcare System in accordance with a mutually agreed upon scope of work.

If after your review you have any questions or require additional information, please do not hesitate to telephone me at the Citadel Office in Valencia at 661.257.9009.

Sincerely, CITADEL ENVIRONMENTAL SERVICES, INC.

Michael K. Roy, CAC 092-0459, LRCIA 7215 Senior Associate – Building Sciences

Enclosure

151 Kalmus Drive, F4, Costa Mesa, California 92626 / P 714.547.4301 / F 714.547.4647 www.citadelenvironmental.com

Michael K. Roy

CITADEL REPORT NO. 5137.1148.0

LIMITED LEAD (XRF) SURVEY REPORT

DEPARTMENT OF VETERANS AFFAIRS SAN DIEGO HEALTHCARE SYSTEM

SAN DIEGO, CALIFORNIA

DECEMBER 27, 2013

DEPARTMENT OF VETERANS AFFAIRS SAN DIEGO HEALTHCARE

SYSTEM

3350 La Jolla Village Drive San Diego, California 92161

Limited Lead (XRF) Survey Report

December 27, 2013

Citadel Project Number 5137.1148.0

Department of Veterans Affairs San Diego Healthcare System VA Medical Center – Building 1 3350 La Jolla Village Drive San Diego, California 92161 www.citadelenvironmental.com

151 Kalmus Drive, F4, Costa Mesa, California 92626 / P 714.547.4301 / F 714.547.4647 www.citadelenvironmental.com

DEPARTMENT OF VETERANS AFFAIRS SAN DIEGO HEALTHCARE SYSTEM

SAN DIEGO, CALIFORNIA

DECEMBER 27, 2013

Table of Contents

EXECUTIVE SUMMARY

1.0 INTRODUCTION

2.0 SCOPE OF WORK

3.0 BUILDING DESCRIPTION

4.0 SURVEY METHODOLOGIES

5.0 RESULTS

6.0 CONCLUSIONS AND RECOMMENDATIONS

7.0 SURVEY LIMITATIONS

8.0 SIGNATURES

APPENDICES:

A Project Team Certifications B Drawings with Room Testing Locations - Basement through Penthouse C Drawings with Lead Positive (LBP) Sample Locations - First through Sixth Floor

Interstitial Spaces D Table 3.0 - Lead XRF Results E Table 3.1 – Lead XRF Results – LBP (Positive - mg/cm2) F Table 3.2 – LCP – (> 0.01 mg/cm2 and < 1.0 mg/cm2)

DEPARTMENT OF VETERANS AFFAIRS SAN DIEGO HEALTHCARE SYSTEM

SAN DIEGO, CALIFORNIA

DECEMBER 27, 2013

EXECUTIVE SUMMARY

Citadel Environmental Services, Inc. (Citadel) was retained by the Department of Veterans Affairs San Diego Healthcare System (Client) to conduct a Limited Lead (XRF) Survey of the VA Medical Center San Diego Building No. 1 (Survey Area) located at 3350 La Jolla Village Drive in San Diego, California (Site). The limited XRF survey was conducted in accordance with a mutually agreed upon scope of work.

Citadel’s scope of work was to review existing project documentation1, and to identify representative lead paints, coatings, and glazings, herein referred to as “lead-containing materials” (LCM) within the survey area.

The survey was conducted between October 23rd and November 8th, 2013. The survey encompassed select locations of the building interiors of the Basement through Penthouse and the First through Sixth Floor Interstitial Spaces.

Table B.1 below summarizes the materials identified and sampled to be Lead-Containing Paints (LCP) (detectable quantities of lead in concentrations of <5,000 ppm or <1.0 mg/cm2) in the survey area:

TABLE B.1

COMPONENT COLOR SUBSTRATE LOCATION(S)

Refer To Appendix D -----

Table B.2 below summarizes the materials identified and sampled to be Lead-Based Paints (LBP) (detectable quantities of lead in concentrations of >5,000 ppm or >1.0 mg/cm2) in the survey area:

TABLE B.2

COMPONENT COLOR SUBSTRATE LOCATION(S)

First Floor Wall White Ceramic First Floor, 1373, 1374, 1481

Wall White, Tan Drywall/Lead

Sheeting First Floor, 1275, 1307, 1837

Window Frame Gray Metal First Floor, 1307 Door Frame Gray Metal First Floor, 1275

Base Trim White Metal First Floor, 1465

Wall White Plaster/Lead

Sheeting First Floor, 1312, 1842, 1844

Brace Orange Metal First Floor Interstitial, 1014-Mech, 0-9.4, 1015-Mech

Hand Rail Orange Metal First Floor Interstitial Post Orange Metal First Floor Interstitial

Toe Guard Orange Metal First Floor Interstitial Wall Gray Lead Sheeting First Floor Interstitial

1 Client provided Citadel with known locations of lead sheeting, which have been located on the drawings in Appendix B.

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DEPARTMENT OF VETERANS AFFAIRS SAN DIEGO HEALTHCARE SYSTEM

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Second Floor Sink White Ceramic Second Floor, N 2393 Wall White Ceramic Tile Second Floor, W 2067 Wall Light Pink Drywall Second Floor, N 2422 Wall Light Pink Plaster Second Floor, W 2067

Hand Rail Orange Metal Second Floor Interstitial Post Orange Metal Second Floor Interstitial

Toe Guard Orange Metal Second Floor Interstitial Wall Gray Lead Sheeting Second Floor Interstitial

Third Floor Sink Yellow Ceramic Third Floor, E 3251A Wall Gray Ceramic Third Floor, N 3359

Door Frame Green Metal Third Floor Interstitial Post Orange Metal Third Floor Interstitial

Toe Guard Orange Metal Third Floor Interstitial Fourth Floor

Door Gray Metal Fourth Floor, 4070, 4506 Door Frame Gray Metal Fourth Floor, 4070, 4506

Sink White Ceramic Fourth Floor, 4319, 4344

Wall White Drywall/Lead

Sheeting Fourth Floor, 4070, 4506

Ceiling White Concrete Fourth Floor Interstitial Hand Rail Orange Metal Fourth Floor Interstitial

Post Orange Metal Fourth Floor Interstitial Toe Guard Orange Metal Fourth Floor Interstitial

Wall Gray Lead Sheeting Fourth Floor Interstitial Fifth Floor

Panel Tan, White, Gray Plaster Fifth Floor, S. 5101C, S. 5090A, S.

5101B

Wall Tan Drywall Fifth Floor, W. 5032 Wall White Plaster Fifth Floor, W. 5030

Wall White, Blue, Light Green Ceramic

Fifth Floor

Hand Rail Orange Metal Fifth Floor Interstitial Post Orange Metal Fifth Floor Interstitial

Toe Guard Orange Metal Fifth Floor Interstitial Wall Gray Lead Sheeting Fifth Floor Interstitial

Sixth Floor Cabinet Orange Metal Sixth Floor, W. 6022

Door Gray Metal Sixth Floor, W. 6076 Wall Black Plaster Sixth Floor, W. 6076

Hand Rail Orange Metal Sixth Floor Interstitial Post Orange Metal Sixth Floor Interstitial

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Toe Guard Orange Metal Sixth Floor Interstitial Wall Gray Lead Sheeting Sixth Floor Interstitial

Penthouse Base Black Metal Seventh Floor, 7005

Hand Rail Green Metal Seventh Floor, 7005 Motor Dark Green Metal Seventh Floor, 7005 Stairs Green Metal Seventh Floor, 7000 Strips Green Metal Seventh Floor, 7005 Wall Green Plaster Seventh Floor, 7005

Basement Level Door Off-white Ceramic B Level, Dish Area/B128 Trim White Metal B Level, NW Cage Area

Wall Off-white Ceramic B Level, Dish Area/B128, B122, B123

Support Orange Metal B Level, Interstitial

This survey revealed that building components coated with lead are present in areas within the tested areas. At present there is no explicit state or federal regulations requiring mandatory lead removal prior to disturbance or demolition of structures with identified lead materials. However, there are applicable Cal/OSHA worker protection and training requirements, Cal/EPA waste disposal requirements, CDPH requirements for public and residential buildings, and SB 460 lead hazard regulations that apply to lead-related construction activities and their associated wastes.

The survey was limited to the project area as explicitly defined by client and described herein.

Any suspect materials encountered during the course of demolition/renovation activities that were not previously sampled, should be presumed to be LCMs until sampled and proven otherwise.

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DEPARTMENT OF VETERANS AFFAIRS SAN DIEGO HEALTHCARE SYSTEM

SAN DIEGO, CALIFORNIA

DECEMBER 27, 2013

1.0 INTRODUCTION

Citadel Environmental Services, Inc. (Citadel) was retained by the Department of Veterans Affairs San Diego Healthcare System (Client) to conduct a Limited Lead (XRF) Survey of the VA Medical Center San Diego Building No. 1 (Survey Area) located at 3350 La Jolla Village Drive in San Diego, California (Site). The limited XRF survey was conducted in accordance with a mutually agreed upon scope of work.

2.0 SCOPE OF WORK

Citadel’s scope of work was to review existing project documentation2 furnished by the Client and identify representative lead paints, coatings, and glazings, herein “lead-containing materials (LCMs), within the project area. The testing included representative building components in select locations of the building interiors of the Basement through Penthouse and the First through Sixth Floor Interstitial Spaces.

The survey was conducted between October 23rd and November 8th, 2013, by Citadel representatives Nelson N. Ortiz, a California Department of Public Health Services (CDPH) Lead- Related Construction Sampling Technician (LRST #20493) and Amir Baum (CDPH) Lead-Related Construction Inspector/Assessor (LRCIA #24882). The survey was conducted under the general supervision of Michael K. Roy. Mr. Roy is a CDPH LRCIA (#7215). Project team certifications can be found in Appendix A.

2.0 BUILDING DESCRIPTION

The survey area was reportedly constructed between 1968 and 1972, and occupies approximately 1,045,000 square feet within the medical center complex. The survey area is a six-story medical facility, which includes a Penthouse and a Basement, and Interstitial Spaces above the suspended ceilings on each floor that houses building utilities such as electrical and communications systems, medical gases, and the HVAC mechanical systems.

Building No. 1 is a concrete and steel frame truss structure. The interior walls are constructed of sheetrock seamed together with joint compound, troweled-on plaster over welded wire mesh, and unfinished concrete. Wall ceramic tile is present in the Restrooms. Ceiling finishes include various types of mineral fiber-type lay-in ceiling panels, sheetrock seamed together with joint compound, troweled-on plaster over welded wire mesh, spray-applied acoustical finishes (“popcorn ceilings”), and unfinished concrete. Floor finishes include vinyl floor tile (VFT) and vinyl sheet flooring (VSF) adhered with latex adhesives and cutback mastics (FTM), carpeting adhered with latex adhesives, concrete, ceramic tiles, and stone/composite tiles. Vinyl baseboards adhered with latex adhesives are also present in select locations of the building. The exterior finish consists of stucco over welded wire mesh. Roof finishes include rolled felt field membranes and asbestos-containing mastic at penetrations.

2 Client provided Citadel with known locations of lead sheeting, which have been located on the drawings in Appendix B.

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DEPARTMENT OF VETERANS AFFAIRS SAN DIEGO HEALTHCARE SYSTEM

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4.0 SURVEY METHODOLOGIES

Portable XRF Testing Machine (SURVEY)

Citadel utilized X-Ray Florescence Spectrum Analysis (XRF-SA) to test paints, coatings, and glazings in approximately 35% of the estimated total number of rooms (2,000) on floors One through Six.

Building components in approximately 700 rooms were accessed by Citadel for testing. In the Interstitial spaces, paints, coatings, and glazings were tested at approximately 100 locations.

Assays (tests) were taken from interior painted, coated or glazed surfaces to identify the potential presence of lead-based paints (LBPs) and lead-containing paints (LCPs).

Paints, coatings, and glazings that were tested were present on typical building components, such as interior plaster and sheetrock walls, metal doors and frames, ceramic tiles, metal cabinets, toe guards, and handrails, etc. Lead sheeting, used in X-Ray, MRI and other similar locations have been noted as LBP and shown on the drawings.

The XRF irradiates the paint on a given surface causing the lead in the paint, if present, to emit a characteristic frequency of x-ray radiation. The intensity of this radiation is measured by the detector and related to the amount of lead in the paint. The type of XRF used in this survey was a Niton XLP-303A X-Ray Fluorescence Spectrum Analyzer. The XRF analyzer provides an in-the-field determination of suspect LBP without the need to collect substantial numbers of paint chip samples for subsequent laboratory analysis.

In order to obtain a reading, the XRF was placed with the face of the instrument flush against the surface to be tested. It was then held in place for the duration of the sample, which was determined by the instrument. At the conclusion of the sample time, the lead concentration was displayed on the device’s readout screen. The values, expressed in milligrams per square centimeter (mg/cm2), are stored in the device and can be recalled by the inspector upon downloading into computer software. The Niton is sensitive to 0.1 milligrams per square centimeter (mg/cm2) of lead.

The instrument, equipped with a sealed radioactive source, was operated by certified personnel in accordance with manufacturer requirements and applicable regulations. The operator calibrated the XRF-SA pursuant to the manufacturer’s specifications and regularly verified XRF-SA readings against pre-determined lead samples produced by the National Institute of Standards and Testing (NIST). All of these quality control measures produced a 95% confidence level that the XRF-SA readings accurately reflected the actual level of lead in the tested surfaces.

5.0 RESULTS

Lead Definitions

Lead Containing Paint (LCP) - A lead-containing paint is a paint or coating that contains any detectable concentration of lead. LCP is referred to as “negative” (i.e., not a LBP) in the XRF test results in Table 3.0 (all lead testing data) where the results are greater than >0 mg/cm2 and less than 1.0 mg/cm2 (<1.0 mg/cm2); and >0.1 mg/cm2 and <1.0 mg/cm2 in Table 3.2 (LCP testing data).

Lead Based Paint (LBP) – San Diego County, The California Department of Public Health (CDPH) and the US Department of Housing and Urban Development (HUD) define Lead- Based Paint (LBP) as paint containing lead greater than or equal to 1.0 milligram per square centimeter (>mg/cm2) or greater than or equal to 0.5% by weight also expressed as 5,000

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parts per million ( 5,000 ppm). Therefore, for the purposes of this report, XRF-SA readings > 1.0 mg/cm2 are considered LBP.

Lead Containing Material (LCM) - A lead-containing material may consist of identified lead-containing paint (LCP), lead-based paint (LBP), or other materials such as lead sheeting, ceramic tile glazing, etc., or presumed LCMS.

Presumed Lead-Based Paint (PLBP) - Title 17, California Code of Regulations, Division 1, Chapter 8 defines as paint or surface coating affixed to a component in or on a structure constructed prior to January 1, 1978 as a presumed lead-based paint unless it has been tested and found to contain an amount of lead less than one milligram per square centimeter 1.0 mg/cm2 (<1.0 mg/cm2) or less than 0.5% (< 0.5%) by weight.

A total of 6,538 assays (tests) (excluding “Null” and “Calibration Readings”), using the XRF-SA were conducted during the survey. Of the 6,538 assays collected, four-hundred nine (409) were found to contain LBP (i.e., >1.0 mg/cm2). The following LBP components, by percent positive, were identified during the survey:

Component Substrate Number of Surfaces Tested

Number of Positives

(LBP)

Percent Positive

First Floor Wall Ceramic 55 9 16%

Wall Drywall 558 8 1%

Window Frame Metal 16 1 6%

Door Frame Metal 202 1 0.5%

Base Trim Metal 3 3 100%

Wall Plaster 199 5 3%

Brace Metal 3 3 100%

Hand Rail Metal 16 15 94%

Post Metal 16 15 94%

Toe Guard Metal 14 14 100%

Wall Lead Sheeting 6 6 100% Second Floor

Sink Ceramic 17 1 6%

Wall Ceramic Tile 37 3 8%

Wall Drywall 335 1 0.30%

Wall Plaster 28 1 4%

Hand Rail Metal 10 10 100%

Post Metal 10 10 100%

Toe Guard Metal 10 10 100%

Wall Lead Sheeting 9 9 100% Third Floor

Wall Drywall 276 1 0.40%

Sink Ceramic 13 1 8%

Door Frame Metal 1 1 100%

Post Metal 1 1 100%

Toe Guard Metal 1 1 100% Fourth Floor

Door Metal 96 2 2%

Door Frame Metal 95 3 3%

Sink Ceramic 17 2 12%

Wall Drywall 277 5 2%

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Component Substrate Number of Surfaces Tested

Number of Positives

(LBP)

Percent Positive

Ceiling Concrete 25 1 4%

Hand Rail Metal 27 25 93%

Post Metal 27 27 100%

Step Metal 5 1 20%

Toe Guard Metal 28 27 96%

Wall Lead Sheeting 11 11 100% Fifth Floor

Panel Plaster 3 3 100%

Wall Drywall 267 1 0.40%

Wall Plaster 34 1 3%

Wall Ceramic 56 16 29%

Hand Rail Metal 10 10 100%

Post Metal 9 9 100%

Toe Guard Metal 10 9 90%

Wall Lead Sheeting 8 8 100% Sixth Floor

Cabinet Metal 43 1 2%

Door Metal 76 1 1.3%

Wall Ceramic 69 56 81%

Wall Plaster 63 3 5%

Hand Rail Metal 9 9 100%

Post Metal 9 9 100%

Toe Guard Metal 9 9 100%

Wall Lead Sheeting 7 7 100% Penthouse Floor

Base Metal 1 1 100%

Hand Rail Metal 1 1 100%

Motor Metal 1 1 100%

Stairs Metal 2 2 100%

Strips Metal 1 1 100%

Wall Plaster 13 1 8% Basement Level

Door Ceramic 1 1 100%

Trim Metal 3 3 100%

Wall Ceramic 14 11 79%

Support Metal 1 1 100%

Table 3.0, LBP XRF-SA Results may be found in Appendix D; Table 3.1 Lead XRF Results – LBP (Positive > 1.0 mg/cm2) may be found in Appendix E, and Table 3.2 – LCP – (> 0.1 mg/cm2 and < 1.0 mg/cm2) may be found in Appendix F.

Table 1.1 below summarizes the materials identified and sampled to be Lead-Containing Paints (LCP) (detectable quantities of lead in concentrations of <5,000 ppm or <1.0 mg/cm2) in the survey area:

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SAN DIEGO, CALIFORNIA

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TABLE 1.1

COMPONENT COLOR SUBSTRATE LOCATION(S)

REFER TO APPENDIX F -----

Table 1.2 below summarizes the materials identified and sampled to be Lead-Based Paints (LBP) (detectable quantities of lead in concentrations of >5,000 ppm or >1.0 mg/cm2) in the survey area:

TABLE 1.2

COMPONENT COLOR SUBSTRATE LOCATION(S)

First Floor Wall White Ceramic First Floor, 1373, 1374, 1481 Wall White, Tan Drywall First Floor, 1275, 1307, 1837

Window Frame Gray Metal First Floor, 1307 Door Frame Gray Metal First Floor, 1275

Base Trim White Metal First Floor, 1465 Wall White Plaster First Floor, 1312, 1842, 1844

Brace Orange Metal First Floor Interstitial, 1014-Mech, 0-9.4, 1015-Mech

Hand Rail Orange Metal First Floor Interstitial Post Orange Metal First Floor Interstitial

Toe Guard Orange Metal First Floor Interstitial Wall Gray Lead Sheeting First Floor Interstitial

Second Floor Sink White Ceramic Second Floor, N 2393 Wall White Ceramic Tile Second Floor, W 2067 Wall Light Pink Drywall Second Floor, N 2422 Wall Light Pink Plaster Second Floor, W 2067

Hand Rail Orange Metal Second Floor Interstitial Post Orange Metal Second Floor Interstitial

Toe Guard Orange Metal Second Floor Interstitial Wall Gray Lead Sheeting Second Floor Interstitial

Third Floor Wall Gray Drywall Third Floor, E 3251A Sink Yellow Ceramic Third Floor, N 3359

Door Frame Green Metal Third Floor Interstitial Post Orange Metal Third Floor Interstitial

Toe Guard Orange Metal Third Floor Interstitial Fourth Floor

Door Gray Metal Fourth Floor, 4070, 4506 Door Frame Gray Metal Fourth Floor, 4070, 4506

Sink White Ceramic Fourth Floor, 4319, 4344

Wall White Drywall Fourth Floor, 4070, 4506

Ceiling White Concrete Fourth Floor Interstitial

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COMPONENT COLOR SUBSTRATE LOCATION(S)

Hand Rail Orange Metal Fourth Floor Interstitial

Post Orange Metal Fourth Floor Interstitial Toe Guard Orange Metal Fourth Floor Interstitial

Wall Gray Lead Sheeting Fourth Floor Interstitial Fifth Floor

Panel Tan, White, Gray Plaster Fifth Floor, S. 5101C, S. 5090A, S.

5101B

Wall Tan Drywall Fifth Floor, W. 5032 Wall White Plaster Fifth Floor, W. 5030

Wall White, Blue, Light Green Ceramic

Fifth Floor

Hand Rail Orange Metal Fifth Floor Interstitial Post Orange Metal Fifth Floor Interstitial

Toe Guard Orange Metal Fifth Floor Interstitial Wall Gray Lead Sheeting Fifth Floor Interstitial

Sixth Floor Cabinet Orange Metal Sixth Floor, W. 6022

Door Gray Metal Sixth Floor, W. 6076 Wall Black Plaster Sixth Floor, W. 6076

Hand Rail Orange Metal Sixth Floor Interstitial Post Orange Metal Sixth Floor Interstitial

Toe Guard Orange Metal Sixth Floor Interstitial Wall Gray Lead Sheeting Sixth Floor Interstitial

Penthouse Floor Base Black Metal Seventh Floor, 7005

Hand Rail Green Metal Seventh Floor, 7005 Motor Dark Green Metal Seventh Floor, 7005 Stairs Green Metal Seventh Floor, 7000 Strips Green Metal Seventh Floor, 7005 Wall Green Plaster Seventh Floor, 7005

Basement Level Door Off-white Ceramic B Level, Dish Area/B128 Trim White Metal B Level, NW Cage Area

Wall Off-white Ceramic B Level, Dish Area/B128, B122, B123

Support Orange Metal B Level, Interstitial

The drawings with room testing locations on floors Basement through Penthouse can be found in can be found in Appendix B. The drawings with lead positive (LBP) sample locations on the First through Sixth Floor Interstitial Spaces can be found in Appendix C.

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DECEMBER 27, 2013

6.0 CONCLUSIONS AND RECOMMENDATIONS

Lead-Containing Materials/Lead-Based Paints (LCM/LBP)

This survey revealed that building components coated with LCM/LBP are present in the survey area.

At present there is no explicit federal regulations requiring mandatory lead removal prior to disturbance or demolition of structures with identified lead materials. However, there are applicable OSHA worker protection and training requirements, Cal/EPA waste disposal requirements, CDPH requirements for public and residential buildings, and SB 460 lead hazard regulations that apply to lead-related construction activities and their associated wastes.

The following is a brief discussion and summary of applicable regulatory requirements:

OSHA: 29 CFR 1926.62 governs occupational exposure to lead. This regulation requires that prior to initiation of certain activities, referred to as “trigger tasks”, workers must be trained, medically evaluated, and properly fitted with respiratory protection, and protective clothing until statistically reliable personal eight-hour Time Weighted Average (TWA) results indicate lead exposure levels below the Personal Exposure Limit (PEL) for each unique task which disturbs lead-based and lead-containing coatings. This process is known as a Negative Exposure Assessment (NEA). If the result of the exposure assessment is above the Action Level (AL), additional monitoring is required, and if the result is above the PEL, additional exposure monitoring, worker protection (including respirator protection and PPE), training and medical requirements apply. At a minimum, contractors performing any lead in construction work shall have a hand washing station and HEPA vacuum present on the job site.

“Trigger tasks” are tasks that are assumed to exceed the PEL pending an exposure assessment and encompass the majority of construction activities that disturb surface coatings. Examples of “trigger tasks” range from manual paint scraping as a lower expected exposure up to hot work and abrasive blasting as the highest expected exposures, and include any non-listed task that the employer determines may potentially expose employees to lead levels above the AL.

NOTE: “OSHA does not consider any method that relies solely on the analysis of bulk materials or surface content of lead (or other toxic material) to be acceptable for safely predicting employee exposure to airborne contaminates. Without air monitoring results or without the benefit of historical or objective data (including air sampling, which clearly demonstrates that the employee cannot be exposed above the AL during any process, operation, or activity) the analysis of bulk or surface samples cannot be used to determine employee exposure.” OSHA Standard Interpretation dated 5/8/2000.

Furthermore, OSHA states that these rules apply to “any detectable concentration of lead”, without a specified detection level. Due to the Consumer Product Safety Commission currently allowing paint to contain up to 600 parts per million (ppm) of lead for residential consumption and no limits for industrial or commercial coatings, the variation of lead content due to aging and weathering, and the variation of detection limits associated with both paint chip and XRF analysis, all coated surfaces should be treated as potentially containing lead, unless bulk sample analysis indicates that no lead was detected. Positive analytical results can be utilized to indicate that detectable lead is present, but negative XRF results cannot be interpreted as conclusively demonstrating the absence of lead.

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Analytical data can be helpful in evaluation of lead-related environmental risks in general but cannot be used to calculate worker exposures and are not a substitute for employee exposure monitoring. As a result of the above, any employee that works around potential lead-based or lead-containing coatings should have hazard communication training (lead awareness) training and personal exposure air monitoring if they will potentially disturb such coatings. Significant additional certification, notification, and work practices are required for materials found to be “lead-based” or where the operation or process involved results in airborne lead exposures exceeding the PEL.

Any welding, cutting, or heating of metal surfaces containing surface coatings should be conducted in accordance with 29 CFR 1926.354 and 8 CCR 1537. These regulations require surfaces covered with toxic preservatives, and in enclosed areas, be stripped of all toxic coatings for a distance of at least 4 inches, in all directions, from the area of heat application prior to the initiation of such heat application. There are some provisions for conducting hot work on coated surfaces, but only with required respiratory protection such as properly selected supplied air respirators.

Cal/EPA through the Division of Toxic Substance Control (DTSC) regulates disposal of lead hazardous waste (22 CCR Division 4.5, Minimum Standards for Management of Hazardous and Extremely Hazardous Wastes). It is the responsibility of the waste generator to evaluate all waste streams produced and ensure that any resulting wastes that may be hazardous under California and Federal RCRA standards for lead be properly handled, packaged and transported under proper manifest to a permitted hazardous waste storage, treatment and disposal facility.

CDPH: The Department of Public Health (DPH) has specific requirements (Title 17 Sections 35001 thru 36100) for hazard assessment and work involving lead-based paint (LBP) hazards in public or residential structures. These regulations require special certifications, work practices, and notifications for such activities.

Senate Bill 460 (SB 460): An act to amend Section 1941.1 of the Civil Code, and to amend Sections 17961, 17980, and 124130 of, and to add Sections 17920.10, 105251, 105252, 105253, 105254, 105255, 105256, and 105257 to, the Health and Safety Code, relating to lead abatement. This bill allows for fines and criminal penalties to be levied on any person who is found to have performed lead abatement without containment or created a measurable lead hazard based upon current CDPH standards. The testing for this determination can be initiated by any local official. A determination of a lead hazard is not solely based upon the lead content of the paint or coating and can be the result of the disturbance of such materials with low concentrations of lead.

EPA Lead Renovation, Repair, and Paint Rule (40 CFR, Part 745): Beginning in April 2010, contractors performing renovation, repair and painting projects that disturb lead-based paint in homes, child care facilities, and schools built before 1978 must be certified and must follow specific work practices to prevent lead contamination.

7.0 SURVEY LIMITATIONS

The survey was limited to representative locations of the building(s) that were explicitly defined by the Client to be surveyed. Additional suspect materials may be present in concealed or limited access spaces including, but not limited to, above-ceiling areas, within wall cavities, pipe chases, attics, and crawlspaces. Additional materials may be present below or behind equipment, 5137 1148 0_VASD_XRF_Survey_Report_MLC_12-27-13 11

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beneath existing finishes and coverings, or below grade and will only be accessible during the course of partial or full renovation/demolition activities. Care should be exercised when accessing these areas. Any suspect materials encountered during the course of any demolition/renovation activities that were not previously sampled, should be presumed LCMs until sampled and proven otherwise.

This report has been prepared by Citadel Environmental Services, Inc. exclusively for our Client and their Authorized Representatives. The information contained herein pertains only to accessible materials identified at the referenced property at the time of the survey performed in accordance with a mutually agreed upon scope of work. The findings and recommendations presented are based upon observations of present conditions, and may not necessarily indicate future conditions. Citadel Environmental Services, Inc. implies no warranty to the accuracy of information provided them by outside agents and transmitted herein. The information contained herein may not be used, disclosed, or copied without written permission of the Client.

This survey report is not intended to be a stand-alone design document for the solicitation of bids.

This survey report should only be used for developing the scope of work, bid/contract document, and as a reference document.

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8.0 SIGNATURES

Survey Performed by:

(See Field Documentation for Signature)

Amir Baum CDPH Lead-Related Sampling Technician Cert #24882

(See Field Documentation for Signature)

Nelson N. Ortiz CDPH Lead-Related Sampling Technician Cert #20493

Report Prepared by:

Michael K. Roy CDPH Lead-Related Inspector/Assessor Cert #7215

Report Reviewed by:

Michelle Campbell CDPH Lead-Related Project Monitor Cert #20952

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Michael K. Roy

Appendix A Project Team Certifications

Appendix B Drawings With Room Testing Locations