B08_Att_3_ACM___LBP_Survey_RM_Trailer_Results.pdf

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Attached to
Demolish Structures in Multiple Areas, NPS-PINN Federal contract opportunity
Solicitation number
140P8425Q0035
Issued by
Department of the Interior National Park Service Pacific West Region

About this file

This document is a Limited Asbestos and Lead Based Paint Investigation Report prepared for Pinnacles National Park by RSB Environmental and American Environmental Group. The survey was conducted on May 23, 2024, at a portable trailer located at 5000 CA-146 in Paicines, California, with the primary purpose of identifying potential asbestos and lead-based paint hazards prior to planned demolition activities.

The investigation involved collecting twelve bulk samples for asbestos analysis and five XRF readings for lead content. Laboratory results from Eurofins EPK Built Environment Testing showed no asbestos-containing materials (NAD - No Asbestos Detected) and lead levels below 0.1 mg/cm2 in all sampled locations, including drywall, joint compound, ceiling tiles, vinyl sheet flooring, roofing materials, and various wall surfaces. The report recommends no specific abatement actions, as no hazardous materials were identified. The survey was conducted by certified professionals Chris Heffernan (Site Surveillance Technician) and Tim Ryan (Asbestos Consultant), and the results are intended to support the upcoming demolition of the trailer structure.

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Limited Asbestos and Lead Based Paint Investigation Report 5000 CA-146, Paicines, CA 95043

Your Environmental Business Partners

6001 Savoy Dr., Ste. 110 Houston, Texas 77036 Phone: 1.832.291.3473 www.rsbenv.com

6001 SAVOY DRIVE, SUITE 110,

HOUSTON, TEXAS 77036

LIMITED ASBESTOS SURVEY AND LEAS BASED PAINT

INVESTIGATION REPORT

FOR:

5000 CA-146

PAICINES, CALIFORNIA 95043

PREPARED FOR:

PINNACLES NATIONAL PARK

RSB PROJECT NUMBER: 2403403

REPORT DATE: MAY 29, 2024

PREPARED BY:

5655 LINDERO CANYON ROAD, SUITE 701,

WESTLAKE VILLAGE, CALIFORNIA 91362

Limited Asbestos and Lead Based Paint Investigation Report 5000 CA-146, Paicines, CA 95043

Your Environmental Business Partners

6001 Savoy Dr., Ste. 110 Houston, Texas 77036 Phone: 1.832.291.3473 www.rsbenv.com

May 29, 2024

Re: Limited Asbestos Survey and Lead Based Paint Investigation Report

5000 CA-146,

Paicines, California 95043 RSB Project No.: 2403403

To Whom It May Concern:

RSB Environmental (RSB) was retained by Pinnacles National Park to perform Limited Asbestos Survey and Lead Based Paint Investigation Report for the property located at 5000 CA- 146, Paicines, CA 95043 (the “Subject Property”).

RSB Environmental retained American Environmental Group under a subcontractor agreement to perform Asbestos Survey and Lead Based Paint Investigation Report at the Subject Property.

RSB Environmental appreciates the opportunity to provide you professional environmental services. Should you have any questions regarding this report or the property, please feel free to contact us at (832) 291-3473.

Sincerely, Sachin Butala, P.E.

RSB Environmental Firm Registration No.: F-16311

Enclosure cmulye Inserted Text and

Pinnacles National Park, Paicines, CA Limited Asbestos and Lead Survey Report

AEG Project #115805

TABLE OF CONTENTS

SECTION PAGE

1.0 GENERAL BACKGROUND

2.0 INTRODUCTION

3.0 METHODOLOGIES

4.0 ASBESTOS

4.1 ASBESTOS SAMPLING PROTOCOL

4.2 ASBESTOS SAMPLING RESULTS

4.3 RECOMMENDATIONS

5.0 LEAD

5.1 LEAD SAMPLING PROTOCOL

5.2 LEAD SAMPLING RESULTS

5.3 RECOMMENDATIONS

6.0 LIMITATIONS

ATTACHMENT A

ATTACHMENT B

ATTACHMENT C

AEG Project #115805

1.0 GENERAL BACKGROUND

The Subject Property referenced above is a portable trailer building for government use constructed on a raised foundation. The exterior walls appear to be constructed with a combination of wood siding and metal. The interior walls of the building appear to be finished with a combination of wood and gypsum wallboard over wood framing. The floors are covered with a combination of carpet and linoleum with backing in the areas of concern.

AEG’s services were requested due to a planned demolition of the portable trailer building. During AEG’s assessment, the work areas were found to have no damaged building materials.

2.0 INTRODUCTION

AEG conducted a limited asbestos and lead survey at the Subject Property. Sampling was confined to the areas and materials which will be impacted by demolition activities as directed. The sampling was conducted on May 23, 2024, by Chris Heffernan, California Division of Occupational Safety and Health (DOSH) Certified Site Surveillance Technician (CSST) #16-5656 and California Department of Public Health (CDPH) Lead Sampling Technician #2299, under the supervision of Tim Ryan, DOSH Certified Asbestos Consultant (CAC) #06-3979 and CDPH Lead Inspector/Assessor #5104, who are qualified professionals and representatives of AEG.

3.0 METHODOLOGIES

Samples collected for asbestos content were analyzed by Environmental Protection Agency (EPA) Method 600/R-93/116 per the Code of Federal Regulations (CFR) Title 40 Part 763.86 using Polarized Light Microscopy (PLM). Samples were collected and analyzed at the following laboratory:

• Eurofins Built Environment Testing (Eurofins) – Tustin NVLAP - #200757-0 – P. 800- 651-4802 Address: 2841 Dow Avenue, Suite 300, Tustin, CA 92780

4.0 ASBESTOS

4.1 ASBESTOS SAMPLING PROTOCOL

A minimum sample amount per material is collected based on building material type and category (as defined by the EPA, 40 CFR Part 763.86), square footage and similarity (homogeneous in color, texture, and installation dates).

In accordance with EPA protocol, a material is considered to contain asbestos if results of any of the homogenous material samples indicate that asbestos is present. A material shall be considered non asbestos containing only if all samples collected of that material indicate that no asbestos is detected.

AEG Project #115805

Materials containing greater than one percent (>1%) asbestos as determined by Polarized Light Microscopy (PLM) methodology are considered to be asbestos-containing materials (ACM) according to the Environmental Protection Agency (EPA) and California Occupational Safety and Health Administration (Cal-OSHA). These materials are subject to regulatory provisions under 40 CFR 61 and the California Code of Regulations (CCR), Title 8; Section 1529.

Materials containing greater than one tenth of one percent (>0.1%) methodology are considered to be an asbestos-containing construction materials (ACCM) according to California Occupational Safety and Health Administration (Cal-OSHA). These materials are subject to regulatory provisions under the California Code of Regulations (CCR), Title 8; Section 1529. Materials <0.1% by point-count are exempt from EPA regulations; however, Cal-OSHA requires exposure monitoring, wet methods, employee training, and employee hazard communication even when trace asbestos is detected.

4.2 ASBESTOS SAMPLING RESULTS

AEG collected a total of twelve (12) bulk samples that were analyzed by the laboratory for asbestos content. In accordance with EPA bulk sampling method protocols, the laboratory must separate all layers within a single sample that may result in additional separate samples for analysis. A sampling diagram is included as Attachment A, and laboratory analytical results and chain of custody are included as Attachment B. AEG staff certifications and credentials are included in Attachment C.

Table I: Summary of Building Materials Sampled Sample # Location Material Results Est. Qty Cond. Friable

(Y/N) Possible

P- 5 (Y/N)

A-1 Trailer NE Corner

White Joint Compound NAD 100SF* G Y N

A-1 Trailer NE Corner

Cream Tape NAD 100SF* G Y N

A-1 Trailer NE Corner

White Drywall with Brown Paper

NAD 100SF* G Y N

A-2 Trailer E. Wall White Joint Compound with Paint

NAD 100SF* G Y N

A-2 Trailer E. Wall Cream Tape NAD 100SF* G Y N

A-2 Trailer E. Wall White Joint Compound NAD 100SF* G Y N

A-2 Trailer E. Wall White Drywall with Brown Paper

NAD 100SF* G Y N

A-3 Trailer SE.

Corner

White Joint Compound with Paint

NAD 100SF* G Y N

A-3 Trailer SE.

Corner

Cream Tape NAD 100SF* G Y N

A-3 Trailer SE.

Corner

White Joint Compound NAD 100SF* G Y N

A-3 Trailer SE.

Corner

White Drywall with Brown Paper

NAD 100SF* G Y N

Limited Asbestos and Lead Survey Report May 23, 2024

AEG Project #115805

B-4 Trailer-W.

Side

White Ceiling Tile NAD 360SF* G N N

B-5 Trailer-W.

Side

White Ceiling Tile NAD 360SF* G N N

B-6 Trailer-W.

Side

White Ceiling Tile NAD 360SF* G N N

C-7 Trailer Bathroom

Tan Sheet Flooring with Fibrous Backing

NAD 100SF* G N N

C-7 Trailer Bathroom

Yellow Mastic NAD 100SF* G N N

C-8 Trailer Bathroom

Tan Sheet Flooring with Fibrous Backing

NAD 100SF* G N N

C-8 Trailer Bathroom

Yellow Mastic NAD 100SF* G N N

C-8 Trailer Bathroom

Tan Compound NAD 100SF* G N N

C-9 Trailer Bathroom

Tan Sheet Flooring with Fibrous Backing

NAD 100SF* G N N

C-9 Trailer Bathroom

Yellow Mastic NAD 100SF* G N N

D-10 Trailer Roof Black Roofing Shingle with Pebbles

NAD 800SF* G N N

D-10 Trailer Roof Black Roofing Tar NAD 800SF* G N N

D-11 Trailer Roof Black Roofing Shingle with Pebbles

NAD 800SF* G N N

D-11 Trailer Roof Black Roofing Tar NAD 800SF* G N N

D-12 Trailer Roof Black Roofing Shingle with Pebbles

NAD 800SF* G N N

D-12 Trailer Roof Black Roofing Tar NAD 800SF* G N N

LEGEND:

Bold and Underlined - Building Materials containing greater than 1% Asbestos (ACM) = Must be abated by a California Licensed Abatement Contractor and Disposed of as Hazardous Waste

Bold - Building Materials containing greater than 0.1% and less than 1% Asbestos (ACCM) = Must be abated by a California Licensed Abatement Contractor. Rule 1403 requires that all ACM and ACWM with any asbestos content from a renovation site be disposed at a landfill that accepts asbestos.

Italicized - <0.1% or 0.1% asbestos by point-count - This indicates that asbestos was detected by the analyst, but the concentration is below the limits of quantification. This material is not defined as either ACM or ACCM.

No Bold or Italicized - No Asbestos Abatement required = Building Materials that do not contain Asbestos based on the limitations of PLM Analytical Methodology

* - Quantities need to be verified by a contractor.

CH - Chrysotile Asbestos, NAD - No Asbestos Detected G – Good D - Damaged

AEG Project #115805

4.3 RECOMMENDATIONS

☐ If Asbestos Containing Materials or Asbestos-Containing Construction Materials are identified:

A California state licensed Asbestos Abatement Contractor will be required to perform all work that will disturb any asbestos-containing materials (ACMs) and/or asbestos-containing construction materials (ACCMs) as a result of planned or other renovations to the subject property. Abatement activities must be performed by asbestos-trained personnel using proper personal protective equipment and engineering controls. The abatement contractor must comply with all applicable local, state, and federal regulations governing the removal and/or disturbance of ACMs/ACCMs.

☐ Trace-level Asbestos (<0.1% or 0.1%) was identified:

The contractor performing demolition and or impacting these materials must comply with Cal/OSHA asbestos exposure monitoring. Their Hazardous Materials Communication standards must inform their employees that although the material has been deemed below quantifiable limits of asbestos by the standards used; employees should be instructed on wet methods of removal, HEPA Vacuuming, prompt clean-up, and the prevention of raising dust during the course of work.

☒ If No Asbestos Containing Materials are identified (NAD):

No abatement recommendations are required.

5.0 LEAD

5.1 LEAD SAMPLING PROTOCOL

Representative paint chip or other surface coating material samples shall be collected for lead content of each dissimilar building component type which have common substrates and paint, stain, varnish or shellac color.

The State of California, United States Department of Housing and Urban Development (HUD), and EPA define Lead-Based Paint (LBP) as a painted or other surface coating material containing greater than or equal to (>) 5,000 parts per million (ppm) or 1 mg/cm2 per 40 CFR Part 745. The County of Los Angeles has more stringent definition of an LBP by XRF Analyzer of greater than or equal to (>) 0.7 mg/cm2. Painted material or surfaces containing lead levels between 0.1 and 1.0 mg/cm2 or 600 to 5000 ppm of lead however are considered Lead Containing Paint (LCP). LCP removal and disposal must be performed in accordance with California OSHA regulations and can be handled by a regular contractor who has prepared a California OSHA lead compliance plan/program for the protection of its workers. LCP is not a hazard to occupants per the EPA, HUD, and Cal/DPH and thus not regulated by those agencies. City of San Diego, CA Lead Requirements – Ch. Art. Div. 5 4 10 San Diego Municipal Code Chapter 5: Public Safety, Morals

AEG Project #115805 and Welfare (4-2008): A clearance inspection must be performed upon the completion of all activities which disturb or remove paint and after visual inspection (A) Where the paint is presumed lead-based paint covering a surface area and/or (B) Where lead-based paint testing performed on the paint revealed lead levels greater than 5000 ppm or 1.0 mg/cm2. (3) The lead-safe work practice clearance inspection standards shall be performed only by a Certified Lead Related Construction Inspector/Assessor or Project Monitor. (4) All clearance inspection procedures shall be in compliance with 40 Code of Federal Regulations part 745.227, as it may be amended from time to time, and shall meet title 17 of the California Code of Regulations clearance guidelines, as it may be amended from time to time. (Amended 4- 8-2008 by O-19730 N.S;

effective 5-8-2008).

If an X-ray Fluorescence (XRF) Analyzer is used, 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. AEG utilized a 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 lead-based paint inspections utilizing X-ray Fluorescence.

5.2 LEAD SAMPLING RESULTS

AEG collected a total of five (5) XRF readings of surface coating material for lead content analysis.

Analytical results and chain of custody are attached.

Table II: Summary of Lead XRF Readings SPL # Location Component Substrate Color Condition Results

(mg/cm2) L1 Trailer E. Wall Wall Wallboard White Intact <0.1

L2 Trailer Exterior Wall Wood Siding Brown Intact <0.1

L3 Trailer Exterior Wall Metal siding White Intact <0.1

L4 Trailer Bathroom Door Trim Wood Brown Intact <0.1

L5 Trailer door Door Wood White Intact <0.1

AEG Project #115805

LEGEND:

Bold - Building Materials containing equal to or greater than 5000PPM or 1.0 mg/cm2 (0.7 mg/cm2 in Los Angeles County)

Italicized - Building Materials containing less than 5000PPM or 1.0 mg/cm2 (0.7 mg/cm2 in Los Angeles County)

No Bold or Italicized - Building Materials that do not contain Lead based on the limitations of the Analytical Methodology.

5.3 RECOMMENDATIONS

☐ If Lead Based Surface Coating is identified:

A California state licensed Lead Contractor will be required to perform all work that will disturb any LBP as a result of planned or unplanned renovations to the subject property.

If LCP is identified; removal must be performed in accordance with California OSHA regulations and can be handled by a regular contractor who has prepared a California OSHA lead compliance plan/program for the protection of its workers. – Lead-Based Surface Coating.

☐ If Lead Containing Surface Coating is identified:

Materials can be handled by a regular contractor who has prepared a California OSHA lead compliance plan/program for the protection of its workers. – Lead Containing Surface Coating.

☒ If no detectable concentration of Lead Surface Coating was identified:

No abatement recommendations are required. – No Lead Content Detected.

6.0 LIMITATIONS

AEG is committed to providing quality consulting services. However, asbestos survey work is not an exact science. Because there is the possibility of unforeseen or unexpected property, field and/or general conditions, beyond AEG's control, that could potentially affect our work, and/or if there is present concern for the safety of our employees, our consultants, occupants, or to the public at the site, and/or if there are property insurance constraints, we must qualify the services we provide with the following limitations:

• Although reasonable effort was made to sample all accessible suspect materials which will be impacted during the repairs/restoration activities of the damaged areas, additional suspect materials could be located between walls, in voids, or in other concealed areas.

Caution should be exercised regarding these areas. In the event that additional materials are found which have not been sampled, AEG recommends that work stops until those materials can be sampled for asbestos and/or lead content.

AEG Project #115805

• In addition, sampling and laboratory analysis constraints typically hinder the investigation. AEG does not warrant, guarantee, or profess to have the ability to locate or identify all asbestos-containing materials in a facility.

• Confined spaces, and areas determined by AEG's personnel as unsafe to access, are excluded from the scope of work.

• AEG is not, and has no responsibility as, a generator, operator, treater, storer, transporter or disposer of hazardous materials or waste found or identified as a result of AEG's work.

• AEG does not guarantee or warrant that the facility or workplace is safe; nor does AEG's involvement in this property relieve the Client, building owner/operator or tenant of any continuing responsibility of providing a safe facility or living space.

• This report was based on those conditions observed on the day the field evaluation was accomplished. In the event that changes in the nature of the property have occurred, or additional relevant information about the property is subsequently discovered, the findings contained in this report may not be valid unless these changes and additional relevant information are reviewed, and the conclusion of this report is modified and verified in writing.

AEG Project #115805

ATTACHMENT A

SAMPLING DIAGRAM

AEG Project #115805

ATTACHMENT B

LABORATORY ANALYTICAL DATA, AND CHAIN OF CUSTODY

Approved by:

Approved Signatory Danny Li

Report for:

NonAAA Reports American Environmental Group (AEG) 5655 Lindero Canyon Rd.

Suite 701 Westlake Village, CA 91362

Regarding:

Eurofins EPK Built Environment Testing, LLC Project: 115805; 5000 CA-146 Paicines, CA 95043

EML ID: 3652594

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 and tested. 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 EPK Built Environment Testing, LLC ("the Company"), a member of the Eurofins Built Environment Testing group of companies, 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: 05-23-2024

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 200757-0

EMLab ID: 3652594, Page 1 of 4Eurofins EPK Built Environment Testing, LLC

Eurofins EPK Built Environment Testing, LLC 2841 Dow Avenue, Suite 300, Tustin, CA 92780

(833) 465-5857 www.eurofinsus.com/Built Client: American Environmental Group (AEG) C/O: NonAAA Reports Re: 115805; 5000 CA-146 Paicines, CA 95043

Date of Sampling: 05-22-2024 Date of Receipt: 05-23-2024 Date of Report: 05-23-2024

ASBESTOS PLM REPORT

Total Samples Submitted: 12 Total Samples Analyzed: 12

Total Samples with Layer Asbestos Content > 1%: 0

Location: A1, Trailer NE Corner, DW/JC Lab ID-Version‡: 17889843-1

Sample Layers Asbestos Content White Joint Compound ND

Cream Tape ND White Drywall with Brown Paper ND

Composite Non-Asbestos Content: 15% Cellulose Sample Composite Homogeneity: Moderate

Location: A2, Trailer E. Wall, DW/JC Lab ID-Version‡: 17889844-1

Sample Layers Asbestos Content White Joint Compound with Paint ND

Cream Tape ND White Joint Compound ND

White Drywall with Brown Paper ND Composite Non-Asbestos Content: 15% Cellulose Sample Composite Homogeneity: Moderate

Location: A3, Trailer SE. Corner, DW/JC Lab ID-Version‡: 17889845-1

Sample Layers Asbestos Content White Joint Compound with Paint ND

Cream Tape ND White Joint Compound ND

White Drywall with Brown Paper ND Composite Non-Asbestos Content: 15% Cellulose Sample Composite Homogeneity: Moderate

Location: B4, Trailer-W. Side, 12x12 Ceiling Tile Lab ID-Version‡: 17889846-1

Sample Layers Asbestos Content White Ceiling Tile ND

Composite Non-Asbestos Content: 90% Cellulose Sample Composite Homogeneity: Good

EMLab ID: 3652594, Page 2 of 4Eurofins 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 NVLAP, NIST, or any agency of the federal government. The Company 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".

(833) 465-5857 www.eurofinsus.com/Built Client: American Environmental Group (AEG) C/O: NonAAA Reports Re: 115805; 5000 CA-146 Paicines, CA 95043

Date of Sampling: 05-22-2024 Date of Receipt: 05-23-2024 Date of Report: 05-23-2024

ASBESTOS PLM REPORT

Location: B5, Trailer-W. Side, 12x12 Ceiling Tile Lab ID-Version‡: 17889847-1

Sample Layers Asbestos Content White Ceiling Tile ND

Composite Non-Asbestos Content: 90% Cellulose Sample Composite Homogeneity: Good

Location: B6, Trailer-W. Side, 12x12 Ceiling Tile Lab ID-Version‡: 17889848-1

Sample Layers Asbestos Content White Ceiling Tile ND

Composite Non-Asbestos Content: 90% Cellulose Sample Composite Homogeneity: Good

Location: C7, Trailer Bathroom, Vinyl Sheet Floor Lab ID-Version‡: 17889849-1

Sample Layers Asbestos Content Tan Sheet Flooring with Fibrous Backing ND

Yellow Mastic ND Composite Non-Asbestos Content: 20% Cellulose Sample Composite Homogeneity: Moderate

Location: C8, Trailer Bathroom, Vinyl Sheet Floor Lab ID-Version‡: 17889850-1

Sample Layers Asbestos Content Tan Sheet Flooring with Fibrous Backing ND

Yellow Mastic ND Tan Compound ND

Composite Non-Asbestos Content: 20% Cellulose Sample Composite Homogeneity: Moderate

EMLab ID: 3652594, Page 3 of 4Eurofins 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 NVLAP, NIST, or any agency of the federal government. The Company 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

(833) 465-5857 www.eurofinsus.com/Built Client: American Environmental Group (AEG) C/O: NonAAA Reports Re: 115805; 5000 CA-146 Paicines, CA 95043

Date of Sampling: 05-22-2024 Date of Receipt: 05-23-2024 Date of Report: 05-23-2024

ASBESTOS PLM REPORT

Location: C9, Trailer Bathroom, Vinyl Sheet Floor Lab ID-Version‡: 17889851-1

Sample Layers Asbestos Content Tan Sheet Flooring with Fibrous Backing ND

Yellow Mastic ND Composite Non-Asbestos Content: 20% Cellulose Sample Composite Homogeneity: Moderate

Location: D10, Trailer Roof, White Paint/Wallboard Lab ID-Version‡: 17889852-1

Sample Layers Asbestos Content Black Roofing Shingle with Pebbles ND

Black Roofing Tar ND Composite Non-Asbestos Content: 15% Glass Fibers Sample Composite Homogeneity: Moderate

Location: D11, Trailer Roof, Brown Paint/Wood Siding Lab ID-Version‡: 17889853-1

Sample Layers Asbestos Content Black Roofing Shingle with Pebbles ND

Black Roofing Tar ND Composite Non-Asbestos Content: 15% Glass Fibers Sample Composite Homogeneity: Moderate

Location: D12, Trailer Roof, White Paint/Metal Siding Lab ID-Version‡: 17889854-1

Sample Layers Asbestos Content Black Roofing Shingle with Pebbles ND

Black Roofing Tar ND Composite Non-Asbestos Content: 15% Glass Fibers Sample Composite Homogeneity: Moderate

EMLab ID: 3652594, Page 4 of 4Eurofins 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 NVLAP, NIST, or any agency of the federal government. The Company 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

AEG Project #115805

ATTACHMENT C

AEG STAFF CREDENTIALS / CERTIFICATIONS

TECHNICAL DIRECTOR CERTIFICATIONS

Timothy Ryan, CAC

CHRIS HEFFERNAN CSST & Lead Certifications

5000 CA-146, Paicines, CA 95043 - LBP and ACM Cover Letter 1 1.pdf
AEG 115805 Pinnacles National Park- Limited Asbestos and Lead Survey Report (1).pdf
1.0 General Background 4
2.0 Introduction 4
3.0 Methodologies 4
4.0 Asbestos 4
4.1 Asbestos Sampling Protocol 4
4.2 Asbestos Sampling Results 5
4.3 Recommendations 7
5.0 Lead 7
5.1 Lead sampling protocol 7
5.2 Lead sampling results 8
5.3 Recommendations 9
6.0 Limitations 9
Attachment A 11
Attachment B 12
Attachment C 13
1.0 General Background
2.0 Introduction
3.0 Methodologies
4.0 Asbestos
4.1 Asbestos Sampling Protocol
4.2 Asbestos Sampling Results
4.3 Recommendations
5.0 Lead
5.1 Lead sampling protocol
5.2 Lead sampling results
5.3 Recommendations
6.0 Limitations
Attachment A
Attachment B
Attachment C

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