Attachment 5 Asbestos and Lead Based Paint Report.pdf

ASBESTOS & LEAD-BASED PAINT SURVEY REPORT

Hogback Lookout Shasta-Trinity National Forest

Prepared for:

Kelly Nolan, P.E.

Facilities Engineer

Prepared by:

Clay Guzi and Steve West

CAC – 05-3900

IAS – 11153

April 22, 2021

2021-194 Hogback Lookout Page i

TABLE OF CONTENTS

Page

PURPOSE

EXECUTIVE SUMMARY

SURVEY METHODOLOGY

CONCLUSIONS AND RECOMMENDATIONS

APPENDICES

Appendix A Site Maps Appendix B Asbestos Laboratory Data and Chain-of-Custody Appendix C Lead Laboratory Data and Chain-of-Custody

Hogback Lookout Page 1

Asbestos & Lead-Based Paint Survey Report

PURPOSE

Guzi-West personnel submitted asbestos and lead paint samples from the subject structure for analysis in order to determine the presence or absence of these materials at the Shasta Trinity National Forest’s Hogback Lookout, located on Fenders Ferry Rd in

East Shasta County, California. Site vicinity and sample location maps are depicted on the provided in Appendix A; asbestos laboratory data is provided in Appendix B; lead laboratory data is provided in Appendix C.

EXECUTIVE SUMMARY

According to the National Emission Standard for Hazardous Air Pollutants (NESHAP), asbestos-containing building materials (>1% asbestos) must be removed prior to demolition or renovation activities, if the material is considered to be a Regulated

Asbestos-Containing Material (RACM). RACM is generally defined as all friable asbestos containing material and non-friable material, which contains >1% asbestos, and that will become friable during demolition or renovation. A NESHAP notification is required in two circumstances: 1. For any demolition regardless of the presence or absence of asbestos;

NESHAP regulations define a demolition as ‘removing a load-bearing structural member,’ or 2. A renovation that disturbs greater than 160 square feet or 260 linear feet of RACM.

Building materials containing asbestos were identified and will likely be affected by proposed renovation actions; Table 1 at the end of this section provides the asbestos-containing materials identified, their respective concentrations, and approximate quantities. We recommend the asbestos abatement contractor submit a NESHAP notification a minimum of 10 working days prior to conducting any site disturbance activities due to the presence of RACM. Certified asbestos abatement workers must remove the asbestos-containing materials if they will be disturbed as part of the subject project. Alternatively, the flooring and mastic could be left in place and new flooring installed over the existing flooring which would

Hogback Lookout Page 2 prevent disturbance of the asbestos-containing materials. Regardless of the applicability of NESHAP, Cal-OSHA regulations require certified asbestos abatement workers be utilized to abate the materials containing any concentration of asbestos.

Table 1 Asbestos-Containing Materials

Material/Location Asbestos Concentrations (Chrysotile only type detected)

Approximate Quantity

Tan Sheet Vinyl Flooring located throughout

18.0% 160 SF (RACM)

Black Mastic beneath sheet flooring located throughout

3.0% 160 SF

Three federal agencies have regulations that cover renovation work in regards to the presence of painted surfaces containing lead. HUD’s Lead Safe Housing Rule requires specific lead evaluation and hazard control activities for renovations in HUD-assisted target housing; the EPA’s Renovation, Repair, and Painting (RRP) Rule requires that firms performing renovation, repair and painting activities in target housing (which is most pre-1978 housing) or in pre-1978 child-occupied facilities be certified, use trained and certified renovators, and use lead-safe work practices; and, the Federal Occupational

Safety and Health Administration’s (OSHA’s) Lead in Construction standard (29 CFR

1926.62) requires certain procedures for construction work that may expose a worker to lead. Both HUD and the EPA define lead-based paint as paint containing equal to or greater than 5,000 parts per million, ppm, lead. However, the state of California has more stringent standards via the California Code of Regulations, Title 8, Section 1532.1 and maintains their own training and certification program under the California Department of

Public Health. California Code of Regulations, Title 8, Section 1532.1 defines a lead-containing surface coating as a surface coating containing equal to or greater than 600 parts per million lead. The applicability of each agency and regulation depends upon the concentrations of lead identified in painted surfaces, the proposed work, and the condition of painted surfaces and the structure in general at the time of the survey. No lead-based paint was identified in the material samples collected; however, the two paint

Hogback Lookout Page 3 samples collected both contain concentrations of lead greater than 600 ppm and thus are classified as lead-containing surface coatings. Table 2 at the end of this section provides the lead-containing materials identified and their respective concentrations, and EPA classification. Guzi-West recommends all painted surfaces be treated as lead-containing surface coatings due to both samples collected from the proposed renovation area being classified as lead-containing surface coatings. Prospective contractors should have training in accordance with the requirements of Title 8, California Code of Regulations, Section 1532.1 and ensure proper worker protection is utilized during any disturbance of paint containing lead.

Table 2 Painted Surfaces Containing Lead

Material/Location Lead-containing surface coating (ppm)

EPA Classification

Paint on Interior Window Sill and Sash

966.5 ppm Lead-containing surface coating

Paint on ceiling backer board

726.4 ppm Lead-containing surface coating

ASBESTOS & LEAD—SURVEY METHODOLOGY

Guzi-West personnel submitted suspected asbestos-containing building materials collected from the subject structure on April 8, 2021. Following collection of the samples, the samples were double bagged and then sent via overnight delivery to PEL Laboratory, LLC, under chain-of-custody, for identification of asbestos content. Each suspect asbestos-containing material (ACM) identified, was bulk sampled in general accordance with sampling guidelines established by the Environmental Protection Agency and 29

CFR 1926.1101. The following summarizes the sampling procedures utilized.

• Bulk samples were collected by qualified personnel using appropriate sampling tools and leak-tight containers.

Hogback Lookout Page 4

• Decontamination of bulk sampling tools was used to prevent the spread of secondary contamination to subsequent bulk samples.

• Each bulk sample was individually numbered, recorded on a Sample Log, and submitted under chain-of-custody to PEL Laboratory, LLC.

• The locations of all samples were marked on a site map for the project, please see Appendix A.

• The samples were analyzed by Polarized Light Microscopy (PLM) following National Institute of Occupational Safety and Health (NIOSH) Method 9002.

Guzi-West personnel submitted paint chip samples collected from the subject structure on March 2, 2021. The goal for submittal of the paint chip samples is determining the concentrations of lead levels in paint coating samples, comparison of the levels to State and/or Federal standards, and identification of whether levels exceed specified requirements. Paint samples were sent to EPA-certified laboratories for analysis to determine lead percentages by weight, parts per million, or milligrams per sq. centimeters.

All samples for the subject project were sent via overnight registered delivery to SanAir

Technologies Laboratory, Inc. for analysis by test method SW846/M3050B/7000B.

CONCLUSIONS AND RECOMMENDATIONS FOR ASBESTOS & LEAD

As stated above, asbestos-containing materials were identified that will be impacted by proposed renovation activities. Asbestos was identified in the structure’s flooring and the mastic beneath the flooring, please see Appendix B. We recommend the asbestos abatement contractor submit a NESHAP notification a minimum of 10 working days prior to conducting any site disturbance activities that will impact the asbestos-containing sheet vinyl, which is classified as RACM. Certified asbestos abatement workers must remove the asbestos-containing materials if they will be disturbed as part of the subject project.

Alternatively, the flooring and mastic could be left in place and new flooring installed over the existing flooring which would prevent disturbance of the asbestos-containing materials.

No lead-based paint was identified in the two samples at the subject project; but the two samples were identified as lead-containing surface coatings. Please see the lead

Hogback Lookout Page 5 laboratory report provided in Appendix C. Guzi-West recommends all painted surfaces be treated as lead-containing surface coatings due to the samples containing a concentration of lead that classifies them as lead-containing surface coatings.

Prospective contractors should have training in accordance with the requirements of Title

8, California Code of Regulations, Section 1532.1 and ensure proper worker protection is utilized during any disturbance of paint containing lead.

Asbestos and lead regulations are complicated and are subject to change. The intent of the above information is to advise you of some of the regulations that may affect you, but is not intended to be an all-encompassing discussion of asbestos and lead regulations.

The sole purpose of this investigation and of this report is to assess the site with respect to asbestos-containing materials and painted surfaces containing regulated levels of lead.

Guzi-West is not responsible for locating asbestos-containing building materials in inaccessible areas such as behind walls, above hard ceilings, beneath flooring, or underground. This report has been prepared on behalf of and for the exclusive use of

The United States Forest Service, and is subject to and issued in connection with the agreement and the provisions thereof.

APPENDIX A

Site Maps

Vicinity Map

Shasta-Trinity National Forest Created On: Created On: 4/21/2021

Project Number: 2021-194

Pit River

Fenders Ferry Rd

NOT TO SCALE - FOR APPROXIMATION ONLY

Datum: North American Datum 1983 Projection: UTM Zone 10N Cartographer: Seamus Begley Credit: USAD NAIP, US Forest Service, Shasta County

Map (1 of 2)

North

Turn Right for 35N93B - Hogback MTN

Stay Right for 35N93 - Hogback MTN

Turn Right onto 35N46 - Reynolds Basin

Hogback Lookout Lat: 40.8834 deg

Long: -121.9984 deg

Turn onto Fenders Ferry Road

Lat: 40.8234 Long: -121.9315

Round Mountain

CA

Datum: North American Datum 1983 Projection: UTM Zone 10N Cartographer: Seamus Begley Credit: Map Content made by US Forest Service

Hogback Lookout Shasta-Trinity National Forest

Lead Samples Asbestos Samples

Created On: Created On: 4/22/2021 Project Number: 2021-194

Map (2/2)

(-) No Asbestos Detected

NOT TO SCALE - FOR APPROXIMATION ONLY

(+) Contains Asbestos

North

LCSC - Lead Containing Surface Coating

APPENDIX B

Asbestos Laboratory Data and Chain-of-Custody

Client:

Project Name:

Project Address:

Project No.:

Methodology:

T/A Time:

PEL Sample No.

Client

Sample No.:

Composition Color Description

Asbestos

Presence/Absence

& Type (if present)

Non‐Asbestos

Fiber Type

1 101 Layered Tan Flooring Chrysotile 18.00 Cellulose 20

Calcium

Carbonate Binder

1a Layered Black Mastic Chrysotile 3.00 Tar

2 102 Homogeneous White Ceiling Tile No Asbestos Detected Cellulose 55 Binder

Glass Fibers 50

3 103 Homogeneous Brown

Ceiling Tile

Adhesive No Asbestos Detected

Calcium

Carbonate

Analyst

Signature: Date of Report:

Reviewer

Signature: Date of Report:

PEL Laboratories is accredited under the National Voluntary Laboratory Accreditation Program (NVLAP) for performing polarized light microscopy (PLM) analyses under methods known as App. E to Sub. E of 40 CFR Part 762 and EPA/600/R‐93/116. This report must not be used to claim product endorsement by NVLAP or any other agency of the U.S. Government. These results relate only to the samples tested and must not be reproduced, except in full, without the approval of the laboratory. Although PLM analysis is commonly performed to determine the presence or absence of asvestos in building materials, the EPA methods acknowledge that analysis by PLM is subject to limitations and for certain materials, such as vermiculite, a more sophisticated methodology may be necessary.

4/14/2021

4/14/2021

East Shasta County Date Received: 4/12/2021

2 Date Analyzed: 4/15/2021

Guzi‐West PEL Client No.: 2

Hogback Lookout/USFS PEL Work Order No.: 4/14/21‐2

Non‐Fibrous Matrix Types

App. E to Sub. E of 40 CFR Part 763 and EPA/600/R‐93/116 Received By: Chelsea Beattie

3‐day Analyzed By: Chelsea Beattie

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SanAir ID#: 21018410

Project Name: Hogback Lookout/US

Report Date: 4/19/2021

Analysis Report prepared for Guzi-West Inspection & Consulting, LLC

Dear Clay Guzi, We at SanAir would like to thank you for the work you recently submitted. The 2 sample(s) were received on Monday, April 19, 2021 via Fax or Email request. The final report(s) is enclosed for the following sample(s): 201, 202.

These results only pertain to this job and should not be used in the interpretation of any other job. This report is only complete in its entirety. Refer to the listing below of the pages included in a complete final report.

Sincerely, Sandra Sobrino Asbestos & Materials Laboratory Manager SanAir Technologies Laboratory

Final Report Includes:

- Cover Letter

- Analysis Pages

- Disclaimers and Additional Information

Sample conditions:

- 2 samples in Good condition.

1551 Oakbridge Dr. Suite B, Powhatan, VA 23139 | 804.897.1177 | Fax: 804.897.0070 | www.SanAir.com | IAQ@SanAir.com

Project Number:

P.O. Number:

Project Name: Hogback Lookout/US

3/2/2021Collected Date:

4/19/2021 9:23:00 AMReceived Date:

4/19/2021 4:51:48 PM

21018410 SanAir ID Number

FINAL REPORT

Guzi-West Inspection & Consulting, LLCName:

Address: PO Box 492770

Redding, CA 96049

530-515-0922Phone:

Analyst: King, Kristina

Asbestos Bulk PLM EPA 600/R-93/116 Stereoscopic Components

SanAir ID / Description Appearance % Fibrous % Non-fibrous Asbestos Fibers

202 / 21018410-002 Ceiling Backer Board

Green Fibrous

Heterogeneous

80% Cellulose 20% Other None Detected

Analyst:

Analysis Date: 4/19/2021 Date: 4/19/2021

Approved Signatory:

Project Number:

P.O. Number:

Project Name: Hogback Lookout/US

3/2/2021Collected Date:

4/19/2021 9:23:00 AMReceived Date:

4/19/2021 4:51:48 PM

21018410 SanAir ID Number

FINAL REPORT

Guzi-West Inspection & Consulting, LLCName:

Address: PO Box 492770

Redding, CA 96049

Disclaimer

This report is the sole property of the client named on the SanAir Technologies Laboratory chain-of-custody (COC). Results in the report are confidential information intended only for the use by the customer listed on the COC. Neither results nor reports will be discussed with or released to any third party without our client's written permission. The final report shall not be reproduced except in full without written approval of the laboratory to assure that parts of the report are not taken out of context. The information provided in this report applies only to the samples submitted and is relevant only for the date, time, and location of sampling. The accuracy of the results is dependent upon the client’s sampling procedure and information provided to the laboratory by the client. SanAir assumes no responsibility for the sampling procedure and will provide evaluation reports based solely on the sample(s) in the condition in which they arrived at the laboratory and information provided by the client on the COC, such as: project number, project name, collection dates, po number, special instructions, samples collected by, sample numbers, sample identifications, sample type, selected analysis type, flow rate, total volume or area, and start stop times that may affect the validity of the results in this report. Samples were received in good condition unless otherwise noted on the report. SanAir assumes no responsibility or liability for the manner in which the results are used or interpreted. This report does not constitute and shall not be used to claim product certification, approval, or endorsement by NVLAP, NIST, or any other U.S. governmental agencies and may not be certified by every local, state, and federal regulatory agencies.

Samples are held for a period of 60 days. Fibers smaller than 5 microns cannot be seen with this method due to scope limitations.

For NY state samples, method EPA 600/M4-82-020 is performed.

NYELAP Disclaimer:

Polarized- light microscopy is not consistently reliable in detecting asbestos in floor covering and similar non-friable organically bound materials. Quantitative transmission electron microscopy is currently the only method that can be used to determine if this material can be considered or treated as non-asbestos containing.

Asbestos Certifications NVLAP lab code 200870-0 City of Philadelphia: ALL-460 PA Department of Environmental Protection Number: 68-05397 California License Number: 2915 Colorado License Number: AL-23143 Connecticut License Number: PH-0105 Massachusetts License Number: AA000222 Maine License Number: LB-0075, LA-0084 New York ELAP lab ID: 11983 Rhode Island License Number: PCM00126, PLM00126, TEM00126 Texas Department of State Health Services License Number: 300440 Commonwealth of Virginia 3333000323 Washington State License Number: C989 West Virginia License Number: LT000616 Vermont License: AL166318 Louisiana Department of Environmental Quality: 212253, Cert 05088

Revision Date: 8/14/2020

Page 1 of 1Page 4 of 8

APPENDIX C

Lead Laboratory Data and Chain-of-Custody

SanAir ID#: 21017053

Project Name: Hogback Lookout/USFS

Report Date: 4/15/2021

Analysis Report prepared for Guzi-West Inspection & Consulting, LLC

Dear K. Nolan, We at SanAir would like to thank you for the work you recently submitted. The 2 sample(s) were received on Monday, April 12, 2021 via FedEx. The final report(s) is enclosed for the following sample(s): 201, 202.

These results only pertain to this job and should not be used in the interpretation of any other job. This report is only complete in its entirety. Refer to the listing below of the pages included in a complete final report.

Sincerely, Abisola Kasali Metals Laboratory Director SanAir Technologies Laboratory

Final Report Includes:

- Cover Letter

- Analysis on Test Family AA

- Disclaimers and Additional Information

Sample conditions:

- 2 samples in Good condition.

1551 Oakbridge Dr. Suite B, Powhatan, VA 23139 | 804.897.1177 | Fax: 804.897.0070 | www.SanAir.com | IAQ@SanAir.com

Project Number:

P.O. Number:

Project Name: Hogback Lookout/USFS

3/2/2021Collected Date:

4/12/2021 9:00:00 AMReceived Date:

4/15/2021 9:11:41 AM

21017053 SanAir ID Number

FINAL REPORT

Guzi-West Inspection & Consulting, LLCName:

Address: PO Box 492770

Redding, CA 96049

Analyst: Oliver, Hannah

Test Method: SW846/M3050B/7000B

Lead Paint Analysis PAINT µg Pb Sample Size Calculated Sample Sample

Sample Description In Sample (grams) RL Results Results

21017053 - 1 201 108 0.1115 89.7 966.5 0.097 % Int Window Sill & Sash µg/g (ppm) By Weight

21017053 - 2 202 75 0.1032 96.9 726.4 0.073 % Ceiling Backer Board µg/g (ppm) By Weight

Method Reporting Limit <10 µg/0.1 g paint

Signature:

Date: 4/13/2021 Date: 4/14/2021

Sample 202 Contained Substrate.

Reviewed:

Project Number:

P.O. Number:

Project Name: Hogback Lookout/USFS

3/2/2021Collected Date:

4/12/2021 9:00:00 AMReceived Date:

4/15/2021 9:11:41 AM

21017053 SanAir ID Number

FINAL REPORT

Guzi-West Inspection & Consulting, LLCName:

Address: PO Box 492770

Redding, CA 96049

Revision Date 10/20/2020

Disclaimer

SanAir Technologies Laboratory, Inc. participates in the Environmental Lead Accreditation Program (ELAP) administered by AIHA-LAP, LLC (Lab ID162952). Refer to our accreditation certificate or www.aihaaccreditedlabs.org for an up to date list of the Fields of Testing for which we are accredited. SanAir also participates in the State of New York’s DOH-ELAP (Lab Id 11983), and has met the EPA's NLLAP program standards. This report does not constitute endorsement by AIHA-LAP, LLC and/or any other U.S. governmental agencies; and may not be accredited by every local, state or federal regulatory agency.

This report is the sole property of the client named on the SanAir Technologies Laboratory chain-of-custody (COC).

Neither results nor reports will be discussed with or released to any third party without our client’s written permission. Final reports cannot be reproduced, except in full, without written authorization from SanAir

Technologies Laboratory, Inc. The information provided in this report applies only to the samples submitted and is relevant only for the date, time, and location of sampling. SanAir is not responsible for sample collection or interpretation made by others. SanAir assumes no responsibility for information provided by the client on the COC such as project number, project name, collection dates, po number, special instructions, samples collected by, sample numbers, sample identifications, sample type, selected analysis type, flow rate, total volume or area, and start stop times that may affect the validity of the results in this report. SanAir Technologies Laboratory, Inc only assures the precision and accuracy of the data it generates and assumes no responsibility for errors or biasing that occur during collection prior to SanAir’s receipt of the sample(s). SanAir’s Method Detection Limits (MDL) and Reporting Limits

(RL) have been derived using various materials meeting each accrediting agencies’ standards. All quality control results are acceptable unless otherwise noted. Results are not corrected for blanks. For Lead Exposure Limits in

Paint, refer to HUD Guidelines for the Evaluation and Control of Lead-Based Paint Hazards and State and Federal

Regulations, where applicable.

http://www.aihaaccreditedlabs.org/

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