LBP_Survey.pdf

LEAD PAINT SURVEY REPORT

SUBJECT PROPERTY LOCATED AT

BUILDINGS 429, 435 AND 452

MARCH AIR FORCE BASE, CALIFORNIA 92518

PREPARED FOR:

MARCH AIR FORCE BASE

ATTN: MR. YUNG NGUYEN

610 MEYER DRIVE, BUILDING 2403

MARCH AIR FORCE BASE, CALIFORNIA 92518

PREPARED BY:

PROJECT NO. 079042 – LS

SURVEY DATE: AUGUST 28, 2019

REPORT DATE: SEPTEMBER 4, 2019

Attachment 9 to FA466419BA010

Lead Paint Survey Report Buildings 429, 435 and 452

March Air Force Base, California 92518 Project No. 079042-LS

September 4, 2019

TABLE OF CONTENTS

1.0 INTRODUCTION

1.1 Site Description

2.0 SURVEY PURPOSE AND SCOPE

2.1 Lead Paint Survey Methodology

2.2 Lead Paint Inspection

2.3 Lead Paint Sampling

3.0 REGULATORY DEFINITIONS

3.1 Lead Regulatory Standards Summary

4.0 Paint Chip Sampling

5.0 SUMMARY OF LCPS AND LBPS

5.1 Conclusions

5.2 Recommendations

6.0 CERTIFICATION

7.0 LIMITATIONS

TABLE

Table 4-1: Lead Paint Survey Results

Table 5-1: Summary of LCP/LBP Results

ATTACHMENTS

Attachment A: Laboratory Analytical Report(s)

Attachment B: Inspector Certfication(s)

Attachment C: Photographs

FIGURES

Site Drawing

Buildings 429, 435 and 452

March Air Force Base, California 92518 Project No. 079042-LS

September 4, 2019

1.0 INTRODUCTION

On August 28th, 2019, at the request of March Air Force Base (Client) and as authorized by Mr. Yung Nguyen, Titan Environmental Solutions, Inc. (TES) conducted a lead paint survey of Buildings 429, 435 and 452 at the March Air Force Base (Subject Property). The inspector assessed the presence, location, color, and condition of the paint and coatings, which were likely to be disturbed. The survey was conducted by Mr. Rod Bronstein, California Department of Public Health (CDPH) Certified Lead Inspector/Assessor (CDPH #23225). This report provides a summary of the survey activities and findings, as well as conclusions and recommendations.

1.1 Site Description

The Buildings 429, 435 and 452 are located on the March Air Force Base (Subject Property). The structures surveyed included two (2) older airplane hangars and one (1) warehouse building. The exterior of the structures were primarily constructed with concrete, and brick and mortar materials. The structures were built on a concrete slab foundation.

2.0 SURVEY PURPOSE AND SCOPE

The purpose of this survey is to identify and assess the presence of lead-based paint (LBP) on coatings and painted surfaces scheduled for disturbance.

The lead paint survey scope of work was limited to the painted components and materials identified by the Client as being scheduled for disturbance (survey area). The survey scope of work included a visual inspection of the paint and coatings likely to be disturbed, paint chip sampling, and paint chip laboratory analysis via flame atomic absorption spectrophotometry (FAAS). The survey scope did not include destructive investigation methods to identify or sample inaccessible concealed materials (i.e. within wall cavities, pipe chases, encased in concrete, etc.).

2.1 Lead Paint Survey Methodology

The lead paint survey was conducted in accordance with applicable standards including, but not necessarily limited to the following: HUD Guidelines and EPA requirements under TSCA Section 403 (24 CFR Part 35 and 40 CFR Part 745, respectively). The lead paint survey was limited to materials/areas scheduled for disturbance within the survey area as identified by the Client.

The lead paint survey consisted of two (2) primary field activities [(1) visual inspection of the survey area and (2) representative testing/sampling of suspect lead-based paints/lead containing paints (LBP/LCP)], as well as laboratory analysis of paint chip samples and preparation of a survey report.

2.2 Lead Paint Inspection

The lead paint inspection included the following activities: (1) identifying homogenous testing combinations (similar room equivalent, component and substrate) of suspect LBP/LCP and (2) assessing the condition of each homogenous area of suspect LBP/LCP.

Once assessments are made, the paint is assigned a condition. These conditions are defined as follows:

Intact: Paint with no visible deterioration or damage.

Buildings 429, 435 and 452

March Air Force Base, California 92518 Project No. 079042-LS

September 4, 2019

Deteriorated: Paint that is cracking, chalking, flaking, chipping, peeling, non-intact, failed, or otherwise separating from a component.

2.3 Lead Paint Sampling

The lead paint sampling included the following activities: (1) developing a representative testing/sampling plan for each homogenous area of suspect LBP/LCP and (2) collecting representative paint chip samples of each homogenous area of suspect LBP/LCP.

Paint chip sampling is documented by entering the test/sample data on a sampling log, including a description of the material, sample number, location, condition, and estimated quantity. Typically, paint chip sample locations are marked on an 8-1/2 x 11-inch floor plan (not to scale).

3.0 REGULATORY DEFINITIONS

The following is a list of some of regulatory definitions associated with lead paint:

Lead-Based Paints/Coatings (LBP) is defined by the United States Environmental Protection Agency (EPA) and Department of Housing and Urban Development (HUD), as well as the California Department of Public Health (CDPH), as paints/coatings that contain an amount of lead equal to, or in excess of 1.0 mg/cm2, 5,000 parts per million (ppm) or 0.5% by weight.

Presumed Lead-Based Paints (PLBP) is defined by the EPA and CDPH as paints/coatings in or on a structure constructed prior to 1978 unless proven to contain an amount of lead less than

1.0 mg/cm2, 5,000 parts per million (ppm) or 0.5% by weight.

Suspect Lead Containing Paints/Coatings (SLCP) all paints/coatings in or on a structure constructed after 1977 are considered to be suspect lead containing unless proven to contain no detectable concentrations of lead.

Lead Abatement is defined by HUD and CDPH as any set of measures designed to reduce or eliminate lead hazards or lead-based paint permanently or for a minimum of 20 years for public and residential buildings, but does not include containment or cleaning.

Lead Related Construction Work is defined by CDPH as any construction, alteration, painting, demolition, salvage, renovation, repair, or maintenance of any residential or public building, including preparation and cleanup that by using or disturbing lead-containing material or soil, may result in significant exposures of adults or children to lead.

3.1 Lead Regulatory Standards Summary

EPA, HUD, CDPH, the United States Occupational Safety and Health Administration (OSHA), the California Division of Occupational Safety and Health (DOSH), and the California Department of Toxic Substance Control (DTSC) regulate the removal, disturbance and disposal of lead in California. The following is a brief list of these, not all, applicable regulatory standards:

Lead-Based Paints/Coatings (LBP) and Presumed Lead-Based Paints (PLBP):

o CDPH, EPA, HUD, OSHA and DOSH regulate abatement, removal and/or disturbance of

LBP.

Buildings 429, 435 and 452

March Air Force Base, California 92518 Project No. 079042-LS

September 4, 2019 o CDPH requires removal, abatement or disturbance of LBP in public and commercial buildings to be performed by CDPH certified lead workers with a certified lead supervisor using lead safe work practices as prescribed in 17 CCR Division 1, Chapter 8.

o The EPA regulates renovation, repair and painting in target housing constructed prior to 1978 and requires these activities to be performed by a EPA certified renovator using work practices in accordance with the standards prescribed in 40 CFR 745, Subpart E.

o OSHA and DOSH requires removal or disturbance of LBP to be performed by trained workers using work practices in accordance with the standards prescribed in 8 CCR Section 1529.

o DTSC requires waste characterization sampling and analysis prior to disposal of wastes containing LBP to determine if it is hazardous waste.

Lead Containing Paints/Coatings (LCP):

o OSHA and DOSH regulate removal and/or disturbance of LCP.

o OSHA and DOSH requires removal or disturbance of LCP to be performed by trained workers using work practices in accordance with the standards prescribed in 8 CCR Section 1529.

o DTSC requires waste characterization sampling and analysis prior to disposal of wastes containing LCP to determine if it is hazardous waste.

Lead Hazards:

o CDPH requires abatement of any lead hazards in public and commercial buildings.

o EPA and HUD require abatement of any lead hazards in pre-1978 housing.

o OSHA and DOSH require worker protection from any lead hazards.

Please note that the above is not a comprehensive list of regulatory standards/requirements associated with lead disturbance/abatement/removal. There may be additional applicable federal, state and local regulations.

4.0 Paint Chip Sampling

Upon completion of the paint chip sampling activities, the samples were submitted to a California Water Resources Control Board accredited under the Environmental Laboratory Accreditation Program (ELAP Certificated #2322), under proper Chain-of-Custody (COC) documentation. Paint chip sample preparation was conducted in accordance with EPA Method 3050B and analysis was conducted in accordance with EPA Method 7000B using FAAS.

TES collected thirteen (13) paint chip samples in the survey area of the Subject Property, which were analyzed for lead content by AmeriSci Los Angeles located in Carson, California using FAAS analysis. The following table 4-1 provides a summary of the paint chip samples with locations, conditions and laboratory analytical results.

Buildings 429, 435 and 452

March Air Force Base, California 92518 Project No. 079042-LS

September 4, 2019

Table 4-1

Lead Paint Survey Results

Sample No. Location Component Substrate Color Condition1* Lead Content

(ppm) Classification2

B452-01 B452 East Side

South Column Concrete Beige D 30,000 LBP

B452-02 B452 East Side

South Hanger Door Metal

Light Beige

D 1,900 LCP

B452-03 B452 North Side

West Door Metal Brown D 1,800 LCP

B452-04 B452 North Side

East Window Sill Concrete Beige D 380 LCP

B429-01 B429 East Side

South Door Metal Brown D <100 BDL

B429-02 B429 East Side

South Wall Brick Beige D <100 BDL

B429-03 B429 South Side

West Door Metal

Gray Green

D <100 BDL

B429-04 B429 South Side

West Window Glass

Beige / Green

D 34,000 LBP

B435-01 B435 West Side

South Door Metal

Dark Brown

D 65,000 LBP

B435-02 Building 435 West

Side North Window Sill /

Casing Concrete Beige D 75,000 LBP

B435-03 B435 West Side

North Fascia / Flashing

Metal Reddish Brown

D 37,000 LBP

B435-04 B435 East Side

South Door Metal

Gray Green

D 79,000 LBP

B435-05 B435 East Side

North Door Metal

Faded Brown

D <100 BDL

Legend:

ppm = parts per million; milligrams per kilogram (mg/kg) = ppm 1 Paint Condition: I = Intact, D = Deteriorated 2 Classification:

BDL = Below the laboratory Reporting Limit of 100 ppm.

LCP = Lead Containing Paint; concentrations exceeding the laboratory Reporting Limit of 100 ppm.

LBP = Lead-Based Paint; equal to or exceeding 5,000 ppm

* Paint conditions are based on visual observations in survey area. Different conditions may be present in other areas of the Subject Property.

Buildings 429, 435 and 452

March Air Force Base, California 92518 Project No. 079042-LS

September 4, 2019

5.0 SUMMARY OF LCPS AND LBPS

5.1 Conclusions

TES collected a total of thirteen (13) paint chip samples from paint and coatings likely to be disturbed during future renovation and/or demolition activities. Detectable concentrations of lead were identified during the survey and these LCP and LBP components / materials are summarized in the following Table 5-1.

Table 5-1

Summary of Identified LCP/LBP

Sample No. Location Component Substrate Color Condition1* Lead Content

(ppm) Classification2

B452-01 B452 East Side

South Column Concrete Beige D 30,000 LBP

B452-02 B452 East Side

South Hanger Door Metal

Light Beige

D 1,900 LCP

B452-03 B452 North Side

West Door Metal Brown D 1,800 LCP

B452-04 B452 North Side

East Window Sill Concrete Beige D 380 LCP

B429-04 B429 South Side

West Window Glass

Beige / Green

D 34,000 LBP

B435-01 B435 West Side

South Door Metal

Dark Brown

D 65,000 LBP

B435-02 Building 435 West

Side North Window Sill /

Casing Concrete Beige D 75,000 LBP

B435-03 B435 West Side

North Fascia / Flashing

Metal Reddish Brown

D 37,000 LBP

B435-04 B435 East Side

South Door Metal

Gray Green

D 79,000 LBP

Legend:

ppm = parts per million; milligrams per kilogram (mg/kg) = ppm 1 Paint Condition: I = Intact, D = Deteriorated 2 Classification:

BDL = Below the laboratory Reporting Limit of 100 ppm.

LCP = Lead Containing Paint; concentrations exceeding the laboratory Reporting Limit of 100 ppm.

LBP = Lead-Based Paint; equal to or exceeding 5,000 ppm

* Paint conditions are based on visual observations in survey area. Different conditions may be present in other areas of the Subject Property.

5.2 Recommendations

TES has the following recommendations based on the findings of this survey:

In accordance with the California Lead-Based Paint and Lead Hazards Regulation [Title 17, California Code of Regulations (CCR), Division 1, Chapter 8] (Title 17), all lead hazards, including deteriorated LBP, should be abated by a California licensed contractor with CDPH Certified Lead Workers using lead-safe work practices prescribed in Title 17 that do not result in lead hazards.

Buildings 429, 435 and 452

March Air Force Base, California 92518 Project No. 079042-LS

September 4, 2019

In accordance with the Lead Renovation, Repair and Painting Rule [Title 40, Code of Federal Regulations (CFR), Part 745, Subpart E] (Lead RRP Rule), any disturbance of LBP should be performed by a certified renovator with Environmental Protection Agency (EPA) accredited training using work practice standards prescribed in the Lead RRP Rule that do not result in lead hazards.

In accordance with the California Lead in Construction Standard [Title 8, CCR, Section 1532.1] (Title 8), any disturbance of LCP should be performed by lead hazard communication trained workers using work practices prescribed in Title 8 that do not result in exposures above the action level (AL) or permissible exposure limit (PEL).

In accordance with California Department of Toxic Substance Control (DTSC) requirements, all lead containing wastes should be sampled and analyzed for total and leachable lead concentrations and disposed of accordingly based on the waste characterization analytical results.

A CDPH Certified Lead Project Monitor should be contracted to conduct monitoring and clearance of any lead-related construction activities, including but not limited to, abatement, removal, and/or disturbance of LBP/LCP.

Any paints/coatings that have not been identified in this report should be considered suspect LBP/LCP and handled as LBP unless sampled and proven to be non-LBP by a CDPH Certified Lead Inspector/Assessor.

Any LBP/LCP to remain at the Subject Property should be properly managed in-place in accordance with applicable regulations via a Lead Paint Management Plan designed by a CDPH Certified Professional.

All lead activities must be performed in accordance with all applicable federal, state and local regulations, including but not limited to those summarized in this report.

Buildings 429, 435 and 452

March Air Force Base, California 92518 Project No. 079042-LS

September 4, 2019

6.0 CERTIFICATION

This survey, including preparation of this report, was conducted under the direction of Mr. Robert Menald, CDPH Certified Lead Inspector/Assessor and Project Monitor (CDPH #14535) and Mr. Ibrahim M. Sobeih, TES Certified Industrial Hygienist in the Comprehensive Practice by the American Board of Industrial Hygiene (ABIH Certificate #5628CP), undersigned. If you have any questions or require any additional information or services, please contact our office toll free at (888) 948-4826.

Sincerely, Titan Environmental Solutions, Inc.

Robert Menald, (CDPH #14535) CDPH Certified Lead Inspector/Assessor and Project Monitor

Ibrahim M. Sobeih, MS, MSPH, CIH, CAC, FAIHA Director of Industrial Hygiene and Safety

7.0 LIMITATIONS

TES is committed to providing state-of-the-art environmental consulting services that are of the highest quality.

However, lead paint survey work is not an exact science. The possibility of field and general conditions beyond TES control that affect our work or that present a concern for the safety of our employees, our consultants, building occupants and the public at the site, and insurance constraints, requires that we qualify the services we provide with the following limitations:

In accordance with the client specified scope of work, this survey was limited to accessible building materials and areas at the Subject Property identified by the Client, no destructive investigation was performed.

Additional suspect materials located inaccessible areas and/or outside the scope of this survey may be present at the Subject Property.

Reasonable effort is made by TES personnel to locate and sample all suspect hazardous materials.

However, for any building there is the possibility that various types of unique or concealed hazardous materials may exist undetected. In addition, sampling and laboratory analyses constraints typically hinder the investigation. TES does not warrant, guarantee or profess to have the ability to locate or identify all hazardous materials in a building.

Confined spaces and areas determined by TES personnel to be unsafe to access, are excluded from the scope of work.

TES 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 TES work.

Buildings 429, 435 and 452

March Air Force Base, California 92518 Project No. 079042-LS

September 4, 2019

TES does not guarantee or warrant that the Subject Property or workplace are safe, nor does TES involvement in this property relieve the Client, building owner/operator or tenant of any continuing responsibility of providing a safe property or workplace.

This report was based on those conditions observed on the day(s) 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 and recommendations 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.

It is understood that the survey is a non-destructive assessment of potential hazardous materials and is to be used expressly for the purpose of evaluating the risk relative to the expected material disturbance at the Subject Property. Because destructive investigation has not been performed during the survey, the report may not reveal concealed hazardous materials. Subsequently, additional investigation including construction documents review and/or destructive investigation is recommended as a precaution to prevent accidental exposure when construction or demolition is planned for this Subject Property.

It is understood that this is a modified survey and results are limited to the specific areas and materials sampled. This report is not valid for use outside of the specific areas identified by the Client or by individuals not associated with the currently planned work at the Subject Property.

Buildings 429, 435 and 452

March Air Force Base, California 92518 Project No. 079042-LS

September 4, 2019

ATTACHMENT A

Laboratory Analytical Report(s)

(Including Chain of Custody Forms)

Attachment 9 to

FA466419BA010

March Air Force Base, California 92518 Project No. 079042-LS

September 4, 2019

ATTACHMENT B

Inspector Certification(s)

March Air Force Base, California 92518 Project No. 079042-LS

September 4, 2019

ATTACHMENT C

Photographs

Photo Log: Buildings 429, 435 and 452, March AFB

Project No. 079042-LS

Photo 1:

Photo of beige concrete column on

B452.

Photo 2:

Photo of light beige metal hanger door on

B452.

Photo 3:

Photo of beige concrete window sill on B452

Photo 4:

Photo of brown metal door on B429.

Photo 5:

Photo of beige/green window glass on

B429.

Photo 6:

Photo of faded brown metal door on B435.

Photo 7:

Photo of dark brown metal door on B435.

Photo 8:

Photo of gray green metal door on B435.

March Air Force Base, California 92518 Project No. 079042-LS

September 4, 2019

FIGURES

N