Attachment 4 Hazardous Materials Report__Final-021621.pdf

ASBESTOS-CONTAINING

MATERIALS AND XRF LEAD-

BASED PAINT SURVEY

SONNY BONO SALTON SEA NATIONAL WILDLIFE REFUGE

RESIDENCE NO. 07 & VISITOR CENTER RESTROOMS

906 WEST SINCLAIR ROAD

CALIPATRIA, CALIFORNIA 92233

PREPARED FOR:

U.S. Fish & Wildlife Service Department of the Interior, Unified Region 8 906 West Sinclair Road Calipatria, California 92233

(760) 348-5278

PREPARED BY:

InDepth Environmental, Inc.

3954 Murphy Canyon Road, Suite D104 San Diego, California 92123

(858) 430-6662

FEBRUARY 2021

IDE

TABLE OF CONTENTS

SECTION PAGE

Executive Summary .......................................................................................................................... i

1.0 Introduction ......................................................................................................................... i

2.0 Asbestos Sampling Approach and Methodology

Asbestos Definition / Background

Asbestos Sampling Protocol

Asbestos Survey Methodology

Asbestos Analysis

Asbestos Results

Recommendations

3.0 Lead-Based Paint Materials

Overview

Scope of Work

Survey Methodology

XRF Lead-Based Paint Results

4.0 Lead TCLP Waste Stream Sampling Results

5.0 Standard of Care

6.0 Disclaimer

TABLES

TABLE PAGE

Table 2-1. AHERA Sampling Protocol Table 4-1. Waste Stream Analysis Results

APPENDICES

APPENDIX

Appendix A. ACM Summary Results Table

Appendix B. PLM Laboratory Analysis Results

Appendix C. ACM Sampling Location Maps

Appendix D. LBP Components Summary Table

Appendix E. Lead-Based Paint XRF Results

Appendix F. Waste Stream Laboratory Analysis Results

Appendix G. State of California 8552 Forms

Appendix H. Site Photographs

Appendix I. IDE Inspector Certifications i | P a g e

EXECUTIVE SUMMARY

InDepth Environmental, Inc. (IDE) conducted an Asbestos-Containing Materials (ACM) and Lead- Based Survey in support of future renovation activities at a government residence and the Visitor Center restrooms at the Sonny Bono Salton Sea National Wildlife Refuge located at 906 West Sinclair Road, Calipatria, California (the Site). Two building locations were included in this survey: Residence No. 07 (main structure) and the two public restrooms at the Visitor Center. The survey at the Visitor Center was limited to the two public restrooms that have exterior access.

On February 4, 2021, IDE conducted an investigation to identify any suspect ACM and LBP that may be present in exterior and interior components to assist in future planning for renovation/demolition requirements.

Identification of suspect ACM and the collection of samples was performed in accordance with the Environmental Protection Agency Asbestos Hazard Emergency Response Act (AHERA) sample collection strategy and National Emission Standards for Hazardous Air Pollutants (NESHAP) Guidelines. Regulatory guidelines identify suspect materials as those exhibiting homogeneous characteristics and require multiple samples of a suspect homogeneous material to satisfy whether a material contains asbestos.

The survey was conducted on interior and exterior components that may be impacted by future renovation / demolition activities. Based on the analytical results, ACMs were detected in the following materials:

Residence No. 07

Exterior transite siding

Roof penetration mastic (cream sealant over black mastic) – Note: The old roof system could be present under the newer installed metal roofing system.

Spray-applied acoustic ceiling texture

Drywall system

9x9-inch beige floor tiles and associated black mastic (under engineering wood flooring)

Based on the analytical results, no ACMs were detected within sampled materials at the visitor center bathrooms.

ckreiser Highlight

Rectangle ii | P a g e

Any material which is found to contain 0.1% to 1.0%, asbestos is considered an Asbestos-Containing Construction Material (ACCM) per California Department of Occupational Safety and Health regulations. Based on the PLM analysis, no ACCMs were detected at the Site in the sampled suspect materials.

All other suspect materials tested during this survey conducted on February 4, 2021, were analyzed and determined to be non-detect for asbestos. Where asbestos-containing materials have been identified, the materials should be handled in accordance with regulatory guidelines.

A summary table of the suspect ACM sampled at the above listed locations have been provided in Appendix A. A copy of the laboratory analysis report is provided in Appendix B. Sampling location maps are provided in Appendix C.

IDE’s California-Certified Lead Professional conducted survey of exterior and interior components by X-Ray Fluorescent technology (XRF) for LBP components for the Site on February 4, 2021. Those materials that may be impacted by the renovation / demolition activities were sampled by XRF. The regulatory guidelines for an LBP using XRF technology is 1.0 mg / cm². Those components that were tested using the XRF and were found to be at or above this level are considered LBP components for the purpose of this report.

Based on the XRF survey results, the following components were determined to be above the State of California and Federal regulatory guidelines for 1.0 mg / cm² and are considered LBP:

Residence No. 07

Exterior wood door frames and door jambs

Exterior wood window frames and sills

Exterior wood corner trim

Exterior walls and wall trim

Exterior columns, vents, vent frames

Interior kitchen wall (drywall)

Interior kitchen ceramic floor tile

Interior bathroom ceramic wall tile

Interior bathroom walls and wall trim

Interior metal bathtub

Interior bathroom wood window sill ckreiser Callout which ones?

iii | P a g e

Building Office and Visitor Center

Ceramic wall tile – women’s restroom

Metal floor vents – women’s restroom

Metal drain cover – women’s restroom

Ceramic wall tile – men’s restroom

Metal floor vents – men’s restroom

Lead-impacted components were sampled by IDE on February 4, 2020 and submitted for waste stream analysis for lead by Total Threshold Limit Concentration (TTLC). If the TTLC results exceed 1,000 mg/kg wet weight, the sample is further analyzed for lead by Soluble Threshold Limit Concentration (STLC) or based on the initial TTLC results is analyzed directly by Toxicity Characteristic Leaching Procedure (TCLP). TTLC and STLC are California Department of Toxic Substance Control (DTSC) specific testing requirements to determine if the material or component is considered a California-specific hazardous waste. TCLP is the Federal requirement to determine if the waste is to be handled as a federal RCRA classified waste. If the TCLP result is equal to or greater than regulatory level of 5 ppm (milligrams/liter) for lead, then the material is considered a RCRA hazardous waste.

The brown exterior trim components and the beige interior porch trim both exceeded the Federal RCRA hazardous waste criteria. The interior wall between the living room and master bedroom (it is believed to be a former exterior wall and the master bedroom is an addition) should be considered a California-specific lead waste. The ceramic tiles in the visitor restrooms should also be considered a California-specific lead waste.

A summary table of the LBP components identified in the XRF report is provided in Appendix D. The XRF testing results are provided in Appendix E. A copy of the waste stream laboratory report is provided in Appendix F. Appendix G contains a copy of the 8552 Form. Site photographs are provided in Appendix H.

i | P a g e

1.0 INTRODUCTION

InDepth Environmental, Inc. (IDE) conducted an interior and exterior Asbestos-Containing Materials (ACM) and Lead-Based Survey in support of future renovation activities at a government residence and exterior Visitor Center restrooms at the Sonny Bono Salton Sea National Wildlife Refuge located at 906 West Sinclair Road, Calipatria, California (the Site).

On February 4, 2021, IDE conducted an investigation to identify any suspect ACM and LBP that may be present in exterior and interior components to assist in future planning for renovation/ demolition requirements.

The survey, testing, and analysis were performed to identify any materials that may be present at the Site that may require special handling prior to renovation / demolition activities. The details of this survey are provided below.

2 | P a g e

2.0 ASBESTOS SAMPLING APPROACH AND

METHODOLOGY

ASBESTOS DEFINITION / BACKGROUND

Asbestos is derived from the Greek word meaning “inextinguishable.” Asbestos is a fibrous mineral that is mined from the earth in much the same manner as coal, copper, iron, or other minerals. It is a naturally-occurring mineral and not a man-made product. The fibrous veins of asbestos are then extracted from the rock in crushing and milling operations that separates and collects the asbestos fibers in their pure form. These asbestos fibers were then used in building products because of the many desirable properties they exhibit, such as: fire and heat resistance, chemical resistance, insulation purposes and textile strength, as well as being low in conductivity. It is these many desirable applications of asbestos that led to the wide range use of it in building products over the years.

Asbestos fibers are very small and exhibit aerodynamics that allow them to remain airborne for many hours to days. It is the size of the fibers and their ability to remain airborne that make inhalation of asbestos a serious health hazard.

The Environmental Protection Agency (EPA) and the Occupational Health and Safety Administration (OSHA) have enacted many laws which are for the protection of the environment and for the safety of the public from exposure to airborne asbestos fibers. In addition, most, if not all, States, including the State of California, have incorporated the Federal Laws and have enacted their own State Asbestos Laws and Regulations. An ACM is defined as a material containing greater than 1 % asbestos. An Asbestos-Containing Construction Material (ACCM) is a California-specific term and refers to a material that contains greater than 0.1 % asbestos.

ASBESTOS SAMPLING PROTOCOL

The sampling protocol established by the Asbestos Hazard Emergency Response Act (AHERA) was used to determine the required number of samples for this survey based on function (surfacing, thermal system insulation, or miscellaneous materials) and homogeneous building materials. A homogeneous area is defined as an area where a suspect material is uniform in texture and color and appears to be identical in every respect. Even if a material appears to be identical, but is found installed at different time periods, then it would be treated as different suspect materials.

3 | P a g e

Since AHERA became the law in the late 1980s, it is considered the standard-of-the-industry approach for building survey assessments and the collection of suspect asbestos bulk samples. The AHERA protocol was used to determine functional areas and subsequent homogeneous areas of construction in the building. The AHERA protocol was also used in the determination for collection of multiple suspect materials for laboratory identification. It should be noted that IDE exceeds the AHERA sampling protocol in that AHERA only addressed interior components and did not address exterior construction materials.

Three forms of asbestos are typically found in buildings:

sprayed- or toweled-on surfacing materials;

thermal system insulation (insulation on pipes, boilers and other mechanical equipment); and miscellaneous materials such as floor tiles, ceiling tiles, roofing materials, window caulking / glazing, etc.

Table 2-1. AHERA Sampling Protocol

Type of Material Estimated Quantity Required Samples

Sprayed or Troweled-on Surfacing Material

Greater than 5,000 ft2 7

Between 1,000 ft2 and 5,000 ft2 5

Less than 1,000 ft2 3

Thermal System Insulation All Quantities 3 Miscellaneous Materials All Quantities 2

NOTE: These sampling protocol quantities are per functional area and / or homogeneous material.

For example, each pipe run that represents a different functional purpose (hot water, cold water, etc.) is considered a different functional group and homogeneous material and, thus, is sampled accordingly.

ASBESTOS SURVEY METHODOLOGY

All suspect and accessible materials that were observed at the Site were sampled in multiple quantities per the protocol addressed above. Those materials that were not sampled in accordance with this protocol were done at the discretion and experience of the EPA AHERA Building Inspector / California Asbestos Consultant at the Site.

IDE identified suspect materials and developed a sampling strategy following a walk-through visual inspection of the Site. IDE made every attempt to visually assess all structures at the Site included in this survey, as well as to collect all suspect materials identified.

4 | P a g e

Without some renovation records documenting histories of replacement products, the possibility of multiple remodeling or tenant improvements is possible. In the event a sub-flooring system does exist, the bottom layer(s) must be tested for asbestos content prior to removal. In addition, materials may exist in inaccessible or hidden areas of the facility that were not observed, inspected, or were inaccessible during this survey. This inspection was non-destructive in nature; therefore, some hidden areas and / or cavities in the buildings may exist and will only be accessible through demolition. Hidden materials may include, but are not limited to: TSI within wall cavities or crawl spaces, vinyl floor tile or sheet flooring beneath sub-floors, as well as mastics. Any materials that were not identified in this survey report and are discovered during any renovation or demolition activities should be properly sampled and analyzed for asbestos identification.

Once homogeneous suspect materials were identified, IDE began the collection of these materials for submission to the laboratory. IDE made all reasonable efforts to obtain samples from inconspicuous areas, thus limiting the damage to surfaces and materials while still providing ample materials for analysis.

Each sample collected was placed in a plastic bag collection container which was then immediately sealed, labeled, and placed in a larger storage bag. Each sample container was assigned a site-specific sample identification number corresponding to the IDE Field Sample Data Sheet. The Field Sample Data was used to record the sample identification number assigned to each individual sample, the location from where the sample was collected, and the type of material submitted for analysis.

This Field Sample Data Sheet was submitted to the laboratory along with a signed-off chain-of-custody form. The laboratory signs off on the chain-of-custody as having received the samples. Each sample was then logged into the lab’s sample logbook and assigned a specific lab identification number.

ASBESTOS ANALYSIS

All samples collected on February 4, 2021 by IDE for this project were delivered to Eurofins EMLab P&K (EMLab). EMLab is a certified, third-party, independent company and is located at 8304 Clairemont Mesa Boulevard, Suite 103 in San Diego, California 92111. EMLab’s phone number is 866-888-6653.

The samples collected for asbestos analysis were analyzed by a NVLAP-certified laboratory in accordance with methods specified in Appendix E, Subpart E, 40 CFR, Part 763 – “Interim Method for the Determination of Asbestos in Bulk Insulation Samples” (EPA-600/M4-82-020 Dec. 1982) as modified by “Method for the Determination of Asbestos in Bulk Building Materials” (EPA/600/R- 93/116 July 1993).

5 | P a g e

All suspect asbestos bulk samples collected at the Site were submitted for analysis by Polarized Light Microscopy (PLM) with Dispersion Staining Technique. The recognized EPA method for this analysis is EPA 600 / R-93 / 116. Bulk samples were initially examined under stereoscopic microscopes at a magnification of 8X to 50X. Stereoscopic observations of each sample were made and the results were recorded. Samples are then submersed into a dispersion staining fluid with a known refractive index. Each sample is then examined under polarized light using microscopes with a McCrone Dispersion Staining Objective. Optical characteristics of the fibrous material were examined to determine the mineralogy of the fiber. The observed optical characteristics include angle of extinction, sign of elongation, and dispersion staining colors. It is through this method that the lab is able to detect asbestos fibers and to determine the type of asbestos present (if applicable).

Asbestos fiber content is estimated by optically comparing the quantity of non-asbestos material to asbestos fibers. The lower limit of reliable detection using PLM is 1%. Samples that contain more than 1% asbestos are reported in percent ranges. Samples that contain asbestos in a concentration lower than the limit of reliable detection (<1%) are reported as “trace” or “<1%”. Samples in which no asbestos is observed are reported as "No Fibers Were Detected (ND)" or “No Asbestos Detected (NAD)”. It should be noted that Cal-OSHA considers any material containing greater than 0.1% asbestos to be an asbestos-containing construction material (ACCM).

ASBESTOS RESULTS

IDE was provided access to the exterior and interior of the Site for the performance of this ACM survey. Based upon the results of the asbestos bulk samples analysis as determined using the method outlined by EPA specified in Appendix A, subpart F, 40 CFR part 763, section 1, Polarized Light Microscopy, ACMs were detected in the following materials:

Residence No. 07

Exterior transite siding

Roof penetration mastic (cream sealant over black mastic) – Note: The old roof system could be present under the newer installed metal roofing system.

Spray-applied acoustic ceiling texture

Drywall system

9x9-inch beige floor tiles and associated black mastic (under engineering wood-flooring)

Suspect materials sampled at the Visitor Center restrooms were reported to be Non-Detect for asbestos.

6 | P a g e

Any material which is found to contain 0.1% to 1.0%, asbestos is considered an Asbestos-Containing Construction Material (ACCM) per California Department of Occupational Safety and Health regulations. Based on the PLM analysis, no ACCMs were detected at the Site in suspect sampled materials.

It should be noted that IDE observed asbestos electrical wiring in the heating unit in the hall bathroom of the residential structure. Based on this observation there may be more asbestos electrical wiring in the home. The electrical wiring is not sampled for safety reasons.

All other suspect materials tested during this survey conducted on February 4, 2021, were analyzed, and determined to be non-detect for asbestos. A summary table identifying the materials which were sampled and analyzed for asbestos identification is provided in Appendix A. The PLM laboratory analysis results are provided in Appendix B. Sampling location maps are provided in Appendix C.

RECOMMENDATIONS

The identified ACMs should be properly removed during any planned demolition/renovation activities by a California licensed asbestos abatement contractor using workers trained in the safe removal of asbestos. All work must be completed in accordance with local Air Pollution Control District regulations, Federal NESHAP regulations and OSHA Work Classification guidelines. ACM wastes must be disposed of at an approved facility that accepts asbestos-containing waste materials.

Although reasonable effort was made to survey all accessible suspect materials, it should be noted that additional suspect and materials could be located within hidden areas at the Site. If suspect materials are discovered during demolition, the material should be sampled before continuing any demolition or renovation activities.

7 | P a g e

3.0 LEAD-BASED PAINT MATERIALS

OVERVIEW

Lead is a bluish-gray, non-combustible metal that occurs naturally in the earth’s crust. Lead is malleable, ductile, and resistant to corrosion. It is for these basic properties that lead was used as an additive to paints. The use of lead in paints was reduced and eventually phased-out over the years. In pre-1955 paints, lead composed from 25% to 75% of the paint contents. Lead content in paints was gradually reduced until approximately 1977 when the Consumer Product Safety Commission ruled that paints could contain no more than 0.06% lead, and in the Consumer Product Safety Act of 2008 when the level was reduced to 0.009%. This is the same standard that exists today; and, generally paints made after 1978 are considered not to be a lead-based paint

(LBP).

SCOPE OF WORK

The objective of this scope of work was to determine if Lead-Based Paint (LBP) is present. For the purpose of this survey, an XRF survey was conducted. The regulatory guidelines for an LBP using XRF technology is 1.0 mg / cm². Those components that were tested using the XRF and were found to be at or above this level are considered LBP components for the purpose of this report.

SURVEY METHODOLOGY

The testing method employed was XRF using a Niton 300 instrument. The instrument was operated in the “unlimited” mode, where the duration for each test result is determined by a combination of:

the actual reading relative to the designated action level;

the age of the radioactive source; and the substrate on which the sample was collected.

The instrument’s calibration was verified according to the manufacturer’s specifications in compliance with the Performance Characteristic Sheet (PCS) developed for this instrument. The readings from this instrument produce a 95% confidence level that the “lead” reading accurately reflects the actual level of lead in the tested surfaces, relative to the federal action level.

8 | P a g e

IDE utilized modified HUD-recommended inspection strategies as outlined in HUD Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing, Chapter 7: Lead-Based Paint Inspection, 1997 Revision, Chapter V; Inspections in Single Family Housing. Currently, HUD offers the only available guidelines for LBP inspections utilizing XRF.

XRF LEAD-BASED PAINT RESULTS

IDE’s California-Certified Lead Professional conducted survey of exterior and interior components by X-Ray Fluorescent technology (XRF) for LBP components for the Site on February 4, 2021.

Those materials that may be impacted by renovation / demolition activities were sampled by XRF. The regulatory guidelines for an LBP using XRF technology is 1.0 mg / cm². Those components that were tested using the XRF and were found to be at or above this level are considered LBP components for the purpose of this report.

Interior and exterior painted components at the Site were determined to be above the State of California and Federal regulatory guidelines for 1.0 mg / cm². Based on the XRF technology and survey results, the following components were found to LBP:

Residence No. 07

Exterior wood door frames and door jambs

Exterior wood window frames and sills

Exterior wood corner trim

Exterior walls and wall trim

Exterior columns, vents, vent frames

Interior kitchen wall (drywall)

Interior kitchen ceramic floor tile

Interior bathroom ceramic wall tile

Interior bathroom walls and wall trim

Interior metal bathtub

Interior bathroom wood windowsill – hall bathroom

9 | P a g e

Visitor Center Restrooms

Ceramic wall tile – women’s restroom

Metal floor vents – women’s restroom

Metal drain cover – women’s restroom

Ceramic wall tile – men’s restroom

Metal floor vents – men’s restroom

Materials that were found to be LBP will require special handling during renovation activities.

Worker protection is required when handling lead-impacted components during demolition/renovation activities. A summary table identifying the building components that were determined to be LBP is provided in Appendix C. The XRF results are provided in Appendix D.

Although reasonable effort was made to survey all accessible exterior and interior painted components, it should be noted that additional components could be located within hidden areas at the Site. If suspect materials are discovered during demolition, the material should be tested before continuing renovation activities.

4.0 LEAD TCLP WASTE STREAM SAMPLING RESULTS

LBP was detected through XRF technology to be present on several exterior and interior components at the structures.

Lead-impacted components were sampled by IDE on February 4, 2020 and submitted for waste stream analysis for lead by Total Threshold Limit Concentration (TTLC). If the TTLC results exceed 1,000 mg/kg wet weight, the sample is further analyzed for lead by Soluble Threshold Limit Concentration (STLC) or based on the initial TTLC results is analyzed directly by Toxicity Characteristic Leaching Procedure (TCLP). TTLC and STLC are California Department of Toxic Substance Control (DTSC) specific testing requirements to determine if the material or component is considered a California-specific hazardous waste. TCLP is the Federal requirement to determine if the waste is to be handled as a federal RCRA classified waste. If the TCLP result is equal to or greater than regulatory level of 5 ppm (milligrams/liter) for lead, then the material is considered a RCRA hazardous waste.

Table 4-1 below summarizes the waste stream analysis results.

10 | P a g e

Table 4-1. Waste Stream Analysis Results

Sample # Sample Description TTLC Lead (mg/kg)

TCLP Lead (mg/L)

TCLP Regulatory Level, Lead

(mg/L)

WS #1 Exterior brown wood trim – residential structure

37,000 23 5.0

WS #2 Exterior beige trim – wood on porch of residential structure

17,000 74 5.0

WS #3 Interior wall between living room and master bedroom – residential structure

2,600 1.4 5.0

WS #4 Kitchen/dining room - ceramic floor tiles 290 0.29 5.0 WS #5 Ceramic tile – hallway bathroom residential structure 410 .011 5.0

WS #6 Ceramic tile – restrooms visitor center 9,100 0.90 5.0

Exterior wood trim components on Residence No. 07 were reported as 37,000 mg/kg and 17,000 mg/kg respectively by TTLC analysis. Due to the TTLC results exceeding the regulatory guideline of 1,000 mg/kg additional analysis was conducting by TCLP. The brown exterior trim components (WS-#1) and the beige interior porch trim (WS-#2) exceeded the regulatory level of 5 mg/L for lead and are considered a Federal RCRA hazardous waste.

The interior wall between the living room/master bedroom (WS-#3) and the ceramic tiles within the visitor center bathrooms (WS-#6) exceeded the 1,000 mg/kg regulatory guideline for lead wastes but were below the regulatory level of 5 mg/L for lead by TCLP. These components are considered to be a California lead waste.

The kitchen/dining room ceramic tiles (WS-#4) and Ceramic tile within the hallway bathroom of the main house (WS-#5) were below the 1,000 mg/kg threshold for lead-regulated waste and can be handled as general construction debris.

A copy of the laboratory analysis for lead waste stream analysis is provided in Appendix F.

11 | P a g e

5.0 STANDARD OF CARE

The services performed by IDE on this project were conducted by certified professionals and have been conducted with that level of care of skill ordinarily exercised by reputable members of the industrial hygiene profession practicing in the same locality under similar budget and time constraints. The survey was non-destructive in scope. No other warranty is expressed or implied.

The lead XRF survey was conducted by an EPA-trained and State of California-licensed Lead professional with specific training in XRF technology.

6.0 DISCLAIMER

The work in this report is for the sole benefit of U.S. Fish and Wildlife Service and its affiliates and assigns and may not be relied upon by any other person or entity. The findings and conclusions for this work are limited in time to when the survey was conducted and scope to the circumstances.

This is provided as a survey report for the properties, and not authored to be an abatement specification for the abatement or demolition contractor.

Preformed and Prepared By:

Steven Atkins, CAC, LIRA, CMC Vice President

Christopher P. Ostwald, CMC, CAC, LST Senior Project Manager

APPENDIX A

SAMPLE RESULTS SUMMARY TABLE

Gray stucco ND Tan skim coat ND Gray stucco ND Tan skim coat ND Gray stucco ND Tan skim coat ND White ceramic tile ND Cream grout ND White ceramic tile ND Cream grout ND Beige drywall with brown paper ND White joint compound ND Cream tape ND White compound ND Beige drywall with brown paper ND White joint compound ND Cream tape ND White compound ND Beige drywall with brown paper ND White joint compound ND Cream tape ND White compound with paint ND

10 Residence - exterior transite siding Gray transite siding 20% Chrysotile 11 Residence - exterior felt paper Black felt ND 12 Residence - exterior transite siding Gray transite siding 20% Chrysotile 13 Residence - exterior felt paper Black felt ND 14 Residence - exterior transite siding Gray transite siding 20% Chrysotile 15 Residence - exterior felt paper Black felt ND 16 Residence - exterior concrete walkway Gray concrete ND 17 Residence - white sealant HVAC - west side White sealant ND 18 Residence - white sealant HVAC - west side White sealant ND 19 Residence - white sealant HVAC - west side White sealant ND 20 Residence - beige seam tape HVAC - west side Beige tape ND 21 Residence - beige seam tape HVAC - west side Beige tape ND 22 Residence - white sealant HVAC - east side White sealant ND 23 Residence - white sealant HVAC - east side White sealant ND 24 Residence - white sealant HVAC - east side White sealant ND 25 Residence - brown/beige HVAC tape - east side Beige tape ND 26 Residence - roof penetration sealant Cream sealant ND 27 Residence - roof penetration sealant Cream sealant ND

Cream sealant ND Black roofing mastic 4% Chrysotile

29 Residence - silver paint on back concrete patio Silver paint ND 30 Residence - silver paint on back concrete patio Silver paint ND 31 Residence - textured popcorn ceiling - living room White ceiling texture ND 32 Residence - textured popcorn ceiling - bedroom #2 White ceiling texture ND

33 Residence - textured popcorn ceiling - bedroom #3 Off-white ceiling texture 3% Chrysotile

34 Residence - textured popcorn ceiling - master bedroom White ceiling texture ND

Restroom building - exterior stucco 1-RR

2-RR Restroom building - exterior stucco

3-RR Restroom building - exterior stucco

Appendix A - Sample Results Summary Table

906 West Sinclair Road, Calipatria, California Sample Number

Sample Location Sample Description Result

4-RR Restroom building - ceramic wall tiles with grout

5-RR Restroom building - ceramic wall tiles with grout

Restroom building - drywall system7-RR

28 Residence - roof penetration sealant

8-RR Restroom building - drywall system

9-RR Restroom building - drywall system

Sonny Bono Salton Sea National Wildlife Refuge

Appendix A - Sample Results Summary Table

906 West Sinclair Road, Calipatria, California Sample Number

Sample Location Sample Description Result

Sonny Bono Salton Sea National Wildlife Refuge

35 Residence - textured popcorn ceiling - kitchen nook White ceiling texture ND

White drywall with brown paper ND Off-white compound with paint 2% Chrysotile White drywall with brown paper ND Off-white compound with paint 2% Chrysotile White drywall with brown paper ND Off-white compound with paint 2% Chrysotile

39 Residence - kitchen drywall system White drywall with brown paper and paint ND

40 Residence - master bedroom drywall system White drywall with brown paper and paint ND

41 Residence - sheet vinyl - bedroom #1 closet Brown sheet flooring with fibrous backing ND

42 Residence - sheet vinyl - bedroom #1 closet Brown sheet flooring with fibrous backing ND

43 Residence - sheet vinyl - bedroom #1 closet Brown sheet flooring with fibrous backing ND

Beige floor tile 4% Chrysotile Black mastic 7% Chrysotile Beige floor tile 4% Chrysotile Black mastic 7% Chrysotile Beige floor tile 4% Chrysotile Black mastic 7% Chrysotile

47 Residence - vinyl sheet flooring - master bedroom closet

Tan sheet flooring with fibrous backing ND

48 Residence - vinyl sheet flooring - laundry room Tan sheet flooring with fibrous backing ND 49 Residence - vinyl sheet flooring - back bathroom Tan sheet flooring with fibrous backing ND 50 Residence - blown-in attic insulation Brown insulation ND 51 Residence - blown-in attic insulation Brown insulation ND 52 Residence - blown-in attic insulation Brown insulation ND

Black baseboard ND Yellow mastic ND Black baseboard ND Yellow mastic ND Black baseboard ND Yellow mastic ND

56 Residence - ceramic tile floor - kitchen / dining room Beige ceramic tile ND

White compound ND Yellow mastic ND White compound ND Yellow mastic ND White compound ND Yellow mastic ND Pink ceramic tile ND White grout ND

Residence - bedroom #3 drywall system

59 Residence - vinyl cove base and mastic - dining room

Residence - ceramic tile and grout - hall bathroom60

*ND = No Asbestos Fibers Detected

58 Residence - vinyl cove base and mastic - dining room

54 Residence - vinyl cove base - master bathroom

55 Residence - vinyl cove base - master bathroom closet

46 Residence - 9"x9" floor tiles with black mastic

Residence - vinyl cove base and mastic - dining room57

Residence - vinyl cove base - laundry53

38 Residence - living room drywall system

Residence - 9"x9" floor tiles with black mastic44

45 Residence - 9"x9" floor tiles with black mastic

Residence - bedroom #2 drywall system36

APPENDIX B

PLM LABORATORY ANALYSIS RESULTS

Approved by:

Approved Signatory Ahmed Fageer

Report for:

Mr. Steve Atkins InDepth Environmental, Inc.

3954 Murphy Canyon Road, Suite D104 San Diego, CA 92123

Regarding: Project: Sonny Bono Salton Sea NWR; Restroom Facilities

EML ID: 2571066

All samples were received in acceptable condition unless noted in the Report Comments portion in the body of the report. The results relate only to the samples as received. The results include an inherent uncertainty of measurement associated with estimating percentages by polarized light microscopy. Measurement uncertainty data for sample results with >1% asbestos concentration can be provided when requested.

Eurofins EMLab P&K ("the Company") shall have no liability to the client or the client's customer with respect to decisions or recommendations made, actions taken or courses of conduct implemented by either the client or the client's customer as a result of or based upon the Test Results. In no event shall the Company be liable to the client with respect to the Test Results except for the Company's own willful misconduct or gross negligence nor shall the Company be liable for incidental or consequential damages or lost profits or revenues to the fullest extent such liability may be disclaimed by law, even if the Company has been advised of the possibility of such damages, lost profits or lost revenues. In no event shall the Company's liability with respect to the Test Results exceed the amount paid to the Company by the client therefor.

Dates of Analysis:

Asbestos PLM: 02-10-2021

Service SOPs: Asbestos PLM (EPA 40CFR App E to Sub E of Part 763 & EPA METHOD 600/R-93-116, SOP EM-AS-S-1267) NVLAP Lab Code 500034-0

EMLab ID: 2571066, Page 1 of 3Eurofins EPK Built Environment Testing, LLC

Eurofins EMLab P&K 8304 Clairemont Mesa Blvd, Suite 103, San Diego, CA 92111

(866) 888-6653 Fax (623) 780-7695 www.emlab.comClient: InDepth Environmental, Inc.

C/O: Mr. Steve Atkins Re: Sonny Bono Salton Sea NWR; Restroom Facilities

Date of Sampling: 02-05-2021 Date of Receipt: 02-05-2021 Date of Report: 02-10-2021

ASBESTOS PLM REPORT

Total Samples Submitted: 8 Total Samples Analyzed: 8

Total Samples with Layer Asbestos Content > 1%: 0

Location: 1-RR, Exterior Stucco Restroom Building Lab ID-Version‡: 12260246-1

Sample Layers Asbestos Content Gray Stucco ND

Tan Skim Coat ND Sample Composite Homogeneity: Moderate

Location: 2-RR, Exterior Stucco Restroom Building Lab ID-Version‡: 12260247-1

Sample Layers Asbestos Content Gray Stucco ND

Tan Skim Coat ND Sample Composite Homogeneity: Moderate

Location: 3-RR, Exterior Stucco Restroom Building Lab ID-Version‡: 12260248-1

Sample Layers Asbestos Content Gray Stucco ND

Tan Skim Coat ND Sample Composite Homogeneity: Moderate

Location: 4-RR, Ceramic Wall Tiles w/Grout Lab ID-Version‡: 12260249-1

Sample Layers Asbestos Content White Ceramic Tile ND

Cream Grout ND Sample Composite Homogeneity: Moderate

EMLab ID: 2571066, Page 2 of 3Eurofins EPK Built Environment Testing, LLC

The test report shall not be reproduced except in full, without written approval of the laboratory. The report must not be used by the client to claim product certification, approval, or endorsement by any agency of the federal government. Eurofins EMLab P&K reserves the right to dispose of all samples after a period of thirty (30) days, according to all state and federal guidelines, unless otherwise specified.

Inhomogeneous samples are separated into homogeneous subsamples and analyzed individually. ND means no fibers were detected. When detected, the minimum detection and reporting limit is less than 1% unless point counting is performed. Floor tile samples may contain large amounts of interference material and it is recommended that the sample be analyzed by gravimetric point count analysis to lower the detection limit and to aid in asbestos identification.

‡ A "Version" indicated by -"x" after the Lab ID# with a value greater than 1 indicates a sample with amended data. The revision number is reflected by the value of "x".

(866) 888-6653 Fax (623) 780-7695 www.emlab.comClient: InDepth Environmental, Inc.

C/O: Mr. Steve Atkins Re: Sonny Bono Salton Sea NWR; Restroom Facilities

Date of Sampling: 02-05-2021 Date of Receipt: 02-05-2021 Date of Report: 02-10-2021

ASBESTOS PLM REPORT

Location: 5-RR, Ceramic Floor Tiles w/Grout Lab ID-Version‡: 12260250-1

Sample Layers Asbestos Content White Ceramic Tile ND

Cream Grout ND Sample Composite Homogeneity: Moderate

Location: 7-RR, Drywall System - Restroom Lab ID-Version‡: 12260251-1

Sample Layers Asbestos Content Beige Drywall with Brown Paper ND

White Joint Compound ND Cream Tape ND

White Compound with Paint ND Composite Non-Asbestos Content: 10% Cellulose Sample Composite Homogeneity: Poor

Location: 8-RR, Drywall System - Restroom Lab ID-Version‡: 12260252-1

Sample Layers Asbestos Content Beige Drywall with Brown Paper ND

White Joint Compound ND Cream Tape ND

White Compound ND Composite Non-Asbestos Content: 10% Cellulose Sample Composite Homogeneity: Poor

Location: 9-RR, Drywall System - Restroom Lab ID-Version‡: 12260253-1

Sample Layers Asbestos Content Beige Drywall with Brown Paper ND

White Joint Compound ND Cream Tape ND

White Compound with Paint ND Composite Non-Asbestos Content: 10% Cellulose Sample Composite Homogeneity: Poor

EMLab ID: 2571066, Page 3 of 3Eurofins EPK Built Environment Testing, LLC

The test report shall not be reproduced except in full, without written approval of the laboratory. The report must not be used by the client to claim product certification, approval, or endorsement by any agency of the federal government. Eurofins EMLab P&K reserves the right to dispose of all samples after a period of thirty (30) days, according to all state and federal guidelines, unless otherwise specified.

Inhomogeneous samples are separated into homogeneous subsamples and analyzed individually. ND means no fibers were detected. When detected, the minimum detection and reporting limit is less than 1% unless point counting is performed. Floor tile samples may contain large amounts of interference material and it is recommended that the sample be analyzed by gravimetric point count analysis to lower the detection limit and to aid in asbestos identification.

‡ A "Version" indicated by -"x" after the Lab ID# with a value greater than 1 indicates a sample with amended data. The revision number is

Approved by:

Approved Signatory Ahmed Fageer

Report for:

Mr. Steve Atkins InDepth Environmental, Inc.

3954 Murphy Canyon Road, Suite D104 San Diego, CA 92123

Regarding: Project: Sonny Bono Salton Sea NWR; Residential Structure

EML ID: 2571059

All samples were received in acceptable condition unless noted in the Report Comments portion in the body of the report. The results relate only to the samples as received. The results include an inherent uncertainty of measurement associated with estimating percentages by polarized light microscopy. Measurement uncertainty data for sample results with >1% asbestos concentration can be provided when requested.

Eurofins EMLab P&K ("the Company") shall have no liability to the client or the client's customer with respect to decisions or recommendations made, actions taken or courses of conduct implemented by either the client or the client's customer as a result of or based upon the Test Results. In no event shall the Company be liable to the client with respect to the Test Results except for the Company's own willful misconduct or gross negligence nor shall the Company be liable for incidental or consequential damages or lost profits or revenues to the fullest extent such liability may be disclaimed by law, even if the Company has been advised of the possibility of such damages, lost profits or lost revenues. In no event shall the Company's liability with respect to the Test Results exceed the amount paid to the Company by the client therefor.

Dates of Analysis:

Asbestos PLM: 02-09-2021 and 02-10-2021

Service SOPs: Asbestos PLM (EPA 40CFR App E to Sub E of Part 763 & EPA METHOD 600/R-93-116, SOP EM-AS-S-1267) NVLAP Lab Code 500034-0

EMLab ID: 2571059, Page 1 of 14Eurofins EPK Built Environment Testing, LLC

(866) 888-6653 Fax (623) 780-7695 www.emlab.comClient: InDepth Environmental, Inc.

C/O: Mr. Steve Atkins Re: Sonny Bono Salton Sea NWR; Residential Structure

Date of Sampling: 02-05-2021 Date of Receipt: 02-05-2021 Date of Report: 02-10-2021

ASBESTOS PLM REPORT

Total Samples Submitted: 51 Total Samples Analyzed: 51

Total Samples with Layer Asbestos Content > 1%: 11

Location: 10, Exterior Transite Siding Lab ID-Version‡: 12260351-1

Sample Layers Asbestos Content Gray Transite Siding 20% Chrysotile

Sample Composite Homogeneity: Good

Location: 11, Exterior Felt Paper Lab ID-Version‡: 12260352-1

Sample Layers Asbestos Content Black Felt ND Composite Non-Asbestos Content: 40% Cellulose Sample Composite Homogeneity: Good

Location: 12, Exterior Transite Siding Lab ID-Version‡: 12260353-1

Sample Layers Asbestos Content Gray Transite Siding 20% Chrysotile

Sample Composite Homogeneity: Good

Location: 13, Exterior Felt Paper Lab ID-Version‡: 12260354-1

Sample Layers Asbestos Content Black Felt ND Composite Non-Asbestos Content: 40% Cellulose Sample Composite Homogeneity: Good

EMLab ID: 2571059, Page 2 of 14Eurofins EPK Built Environment Testing, LLC

The test report shall not be reproduced except in full, without written approval of the laboratory. The report must not be used by the client to claim product certification, approval, or endorsement by any agency of the federal government. Eurofins EMLab P&K reserves the right to dispose of all samples after a period of thirty (30) days, according to all state and federal guidelines, unless otherwise specified.

Inhomogeneous samples are separated into homogeneous subsamples and analyzed individually. ND means no fibers were detected. When detected, the minimum detection and reporting limit is less than 1% unless point counting is performed. Floor tile samples may contain large amounts of interference material and it is recommended that the sample be analyzed by gravimetric point count analysis to lower the detection limit and to aid in asbestos identification.

‡ A "Version" indicated by -"x" after the Lab ID# with a value greater than 1 indicates a sample with amended data. The revision number is

(866) 888-6653 Fax (623) 780-7695 www.emlab.comClient: InDepth Environmental, Inc.

C/O: Mr. Steve Atkins Re: Sonny Bono Salton Sea NWR; Residential Structure

Date of Sampling: 02-05-2021 Date of Receipt: 02-05-2021 Date of Report: 02-10-2021

ASBESTOS PLM REPORT

Location: 14, Exterior Transite Siding Lab ID-Version‡: 12260355-1

Sample Layers Asbestos Content Gray Transite Siding 20% Chrysotile

Sample Composite Homogeneity: Good

Location: 15, Exterior Felt Paper Lab ID-Version‡: 12260356-1

Sample Layers Asbestos Content Black Felt ND Composite Non-Asbestos Content: 40% Cellulose Sample Composite Homogeneity: Good

Location: 16, Exterior Concrete Walkway Lab ID-Version‡: 12260357-1

Sample Layers Asbestos Content Gray Concrete ND

Sample Composite Homogeneity: Good

Location: 17, White Sealant HVAC - West Side Lab ID-Version‡: 12260358-1

Sample Layers Asbestos Content White Sealant ND

Sample Composite Homogeneity: Good

EMLab ID: 2571059, Page 3 of 14Eurofins EPK Built Environment Testing, LLC

The test report shall not be reproduced except in full, without written approval of the laboratory. The report must not be used by the client to claim product certification, approval, or endorsement by any agency of the federal government. Eurofins EMLab P&K reserves the right to dispose of all samples after a period of thirty (30) days, according to all state and federal guidelines, unless otherwise specified.

Inhomogeneous samples are separated into homogeneous subsamples and analyzed individually. ND means no fibers were detected. When detected, the minimum detection and reporting limit is less than 1% unless point counting is performed. Floor tile samples may contain large amounts of interference material and it is recommended that the sample be analyzed by gravimetric point count analysis to lower the detection limit and to aid in asbestos identification.

‡ A "Version" indicated by -"x" after the Lab ID# with a value greater than 1 indicates a sample with amended data. The revision number is

(866) 888-6653 Fax (623) 780-7695 www.emlab.comClient: InDepth Environmental, Inc.

C/O: Mr. Steve Atkins Re: Sonny Bono Salton Sea NWR; Residential Structure

Date of Sampling: 02-05-2021 Date of Receipt: 02-05-2021 Date of Report: 02-10-2021

ASBESTOS PLM REPORT

Location: 18, White Sealant HVAC - West Side Lab ID-Version‡: 12260359-1

Sample Layers Asbestos Content White Sealant ND

Sample Composite Homogeneity: Good

Location: 19, White Sealant HVAC - West Side Lab ID-Version‡: 12260360-1

Sample Layers Asbestos Content White Sealant ND

Sample Composite Homogeneity: Good

Location: 20, Seam Tape (Beige) HVAC West Side Lab ID-Version‡: 12260361-1

Sample Layers Asbestos Content Beige Tape ND

Sample Composite Homogeneity: Good

Location: 21, Seam Tape (Beige) HVAC West Side Lab ID-Version‡: 12260362-1

Sample Layers Asbestos Content Beige Tape ND

Sample Composite Homogeneity: Good

EMLab ID: 2571059, Page 4 of 14Eurofins EPK Built Environment Testing, LLC

The test report shall not be reproduced except in full, without written approval of the laboratory. The report must not be used by the client to claim product certification, approval, or endorsement by any agency of the federal government. Eurofins EMLab P&K reserves the right to dispose of all samples after a period of thirty (30) days, according to all state and federal guidelines, unless otherwise specified.

Inhomogeneous samples are separated into homogeneous subsamples and analyzed individually. ND means no fibers were detected. When detected, the minimum detection and reporting limit is less than 1% unless point counting is performed. Floor tile samples may contain large amounts of interference material and it is recommended that the sample be analyzed by gravimetric point count analysis to lower the detection limit and to aid in asbestos identification.

‡ A "Version" indicated by -"x" after the Lab ID# with a value greater than 1 indicates a sample with amended data. The revision number is

(866) 888-6653 Fax (623) 780-7695 www.emlab.comClient: InDepth Environmental, Inc.

C/O: Mr. Steve Atkins Re: Sonny Bono Salton Sea NWR; Residential Structure

Date of Sampling: 02-05-2021 Date of Receipt: 02-05-2021 Date of Report: 02-10-2021

ASBESTOS PLM REPORT

Location: 22, White Sealant HVAC East Side Lab ID-Version‡: 12260363-1

Sample Layers Asbestos Content White Sealant ND

Sample Composite Homogeneity: Good

Location: 23, White Sealant HVAC East Side Lab ID-Version‡: 12260364-1

Sample Layers Asbestos Content White Sealant ND

Sample Composite Homogeneity: Good

Location: 24, White Sealant HVAC East Side Lab ID-Version‡: 12260365-1

Sample Layers Asbestos Content White Sealant ND

Sample Composite Homogeneity: Good

Location: 25, Brown/Beige HVAC Tape East Side Lab ID-Version‡: 12260366-1

Sample Layers Asbestos Content Beige Tape ND

Sample Composite Homogeneity: Good

EMLab ID: 2571059, Page 5 of 14Eurofins EPK Built Environment Testing, LLC

The test report shall not be reproduced except in full, without written approval of the laboratory. The report must not be used by the client to claim product certification, approval, or endorsement by any agency of the federal government. Eurofins EMLab P&K reserves the right to dispose of all samples after a period of thirty (30) days, according to all state and federal guidelines, unless otherwise specified.

Inhomogeneous samples are separated into homogeneous subsamples and analyzed individually. ND means no fibers were detected. When detected, the minimum detection and reporting limit is less than 1% unless point counting is performed. Floor tile samples may contain large amounts of interference material and it is recommended that the sample be analyzed by gravimetric point count analysis to lower the detection limit and to aid in asbestos identification.

‡ A "Version" indicated by -"x" after the Lab ID# with a value greater than 1 indicates a sample with amended data. The revision number is

(866) 888-6653 Fax (623) 780-7695 www.emlab.comClient: InDepth Environmental, Inc.

C/O: Mr. Steve Atkins Re: Sonny Bono Salton Sea NWR; Residential Structure

Date of Sampling: 02-05-2021 Date of Receipt: 02-05-2021 Date of Report: 02-10-2021

ASBESTOS PLM REPORT

Location: 26, Roof Penetration Sealant Lab ID-Version‡: 12260367-1

Sample Layers Asbestos Content Cream Sealant ND

Sample Composite Homogeneity: Good

Location: 27, Roof Penetration Sealant Lab ID-Version‡: 12260368-1

Sample Layers Asbestos Content Cream Sealant ND

Sample Composite Homogeneity: Good

Location: 28, Roof Penetration Sealant Lab ID-Version‡:…