S1544-03-38_PDC_HAZMAT_Rpt.0620.pdf

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PREPARED FOR:

STATE OF CALIFORNIA

DEPARTMENT OF GENERAL SERVICES

REAL ESTATE DIVISION

707 3RD STREET, 4th FLOOR, MS-504

WEST SACRAMENTO, CALIFORNIA 95605

PREPARED BY:

GEOCON CONSULTANTS, INC.

3160 GOLD VALLEY DRIVE, SUITE 800

RANCHO CORDOVA, CALIFORNIA 95742

GEOCON PROJECT NO. S1544-03-38 JUNE 2020

Project No. S1544-03-38 June 10, 2020

Joe Flores Capital Outlay Program Manager Department of General Services Real Estate Services Division Project Management and Development Branch 707-3rd Street, 4th Floor West Sacramento, California 95605

Subject: HAZARDOUS MATERIALS SURVEY REPORT

THREE RESIDENTIAL BUILDINGS (104, 103, AND 101A/B)

PORTERVILLE DEVELOPMENT CENTER

26501 AVENUE 140 IN PORTERVILLE, TULARE COUNTY, CALIFORNIA

PROJECT NO. 00000 00000 06803

STANDARD AGREEMENT NO. 7455-B, TASK ORDER NO. 36

Dear Mr. Flores:

In accordance with your request, we have performed a hazardous materials (HAZMAT) survey of the subject renovation areas (the Site) in Porterville, California. We performed our services to provide information regarding the potential for asbestos, lead, polychlorinated biphenyls (PCBs), and universal wastes at the Site prior to planned renovation activities.

Our scope of services included surveying the Site for suspect asbestos-containing materials, lead, PCBs, and universal wastes, collecting bulk samples, and submitting the samples to laboratories for analyses.

The accompanying report summarizes the services performed and the results of laboratory analyses.

We appreciate the opportunity to provide our services to the Department of General Services (DGS) on this project. Please contact us if you have any questions concerning this report, or if we may be of further service.

Sincerely, GEOCON CONSULTANTS, INC.

David Watts, CAC (No. 98-2404) John Juhrend, PE, CEG Senior Scientist Senior Engineer

(1 electronic/2 printed) Addressee

TABLE OF CONTENTS

HAZARDOUS MATERIALS SURVEY REPORT PAGE

1.0 INTRODUCTION

1.1 Site Description and Location

1.2 Purpose and Objectives

2.0 REGULATORY BACKGROUND

2.1 Asbestos

2.2 Lead

2.3 PCBs

2.4 Universal Wastes

3.0 SCOPE OF SERVICES

3.1 Asbestos

3.2 Lead

3.3 PCBs

3.4 Universal Wastes

4.0 INVESTIGATIVE RESULTS

4.1 Asbestos

4.1.1 Building 104

4.1.2 Building 103

4.1.3 Building 101A/B

4.2 Lead

4.2.1 Building 104

4.2.2 Building 103

4.2.3 Building 101A/B

4.3 PCBs

4.4 Universal Wastes

4.4.1 Building 104

4.4.2 Building 103

4.4.3 Building 101A/B

5.0 CONCLUSIONS AND RECOMMENDATIONS

5.1 Asbestos

5.1.1 Building 104

5.1.2 Building 103

5.1.3 Building 101A/B

5.2 Lead

5.2.1 Building 104

5.2.2 Building 103

5.2.3 Building 101A/B

5.3 PCBs

5.4 Universal Wastes

6.0 REPORT LIMITATIONS

FIGURES

1. Vicinity Map 2A-C. Site Plans

SITE PHOTOGRAPHS (1 through 60)

TABLE OF CONTENTS (continued)

TABLES

1. Summary of Analytical Laboratory Results – Asbestos

2. Summary of Analytical Laboratory Results – Paint and Ceramic Tile

3. Summary of Analytical Laboratory Results – Polychlorinated Biphenyls

4. Universal Wastes

APPENDICES

A. Personnel Certifications B. Laboratory Reports and Chain-of-custody Documentation

Geocon Project No. S1544-03-38 - 1 - June 10, 2020

HAZARDOUS MATERIALS SURVEY REPORT

1.0 INTRODUCTION

We performed a hazardous materials (HAZMAT) survey of Buildings 104, 103, and 101A/B (the Site) at the Porterville Development Center in Porterville (Tulare County), California, as described herein, for the Department of General Services (DGS) in accordance with Standard Agreement No. 7455-B, Task Order No. 36, dated April 17, 2020.

1.1 Site Description and Location

Renovations areas at the Site consist of the following structures:

Building 104 (a 2-bedroom unit);

Building 103 (a 3-bedroom unit); and

Building 101A/B (a duplex unit).

The approximate site location and structures are depicted on the Vicinity Map (Figure 1), Site

Plans (Figures 2A through 2C), and in the attached photographs.

1.2 Purpose and Objectives

The purpose of our scope of services was to survey for the potential presence and quantity of asbestos, lead-containing paints (LCP), lead-containing ceramic tile, polychlorinated biphenyls (PCBs), and universal wastes at the Site prior to planned renovation activities. The objectives of our survey were to determine asbestos, lead, PCBs, and universal waste significance for providing management and disposal options with respect to minimizing health impacts building staff and occupants, construction workers, and the public during planned renovation.

The information obtained from this investigation will be used by DGS for waste profiling, determining

California Occupational Safety and Health Administration (Cal/OSHA) applicability, and coordinating hazard materials disturbance activities.

It was not Geocon’s intent during this inspection to conduct an evaluation of lead-based paint hazards in accordance with United States Department of Housing and Urban Development (HUD) guidelines.

2.0 REGULATORY BACKGROUND

2.1 Asbestos

The Code of Federal Regulations (CFR), 40 CFR 61, Subpart M, National Emissions Standards for

Hazardous Air Pollutants (NESHAP) and Federal Occupational Safety and Health

Administration (FED OSHA) classify asbestos-containing material (ACM) as any material or product

Geocon Project No. S1544-03-38 - 2 - June 10, 2020 that contains more than 1% asbestos. Nonfriable ACM is classified by NESHAP as either Category I or

Category II material defined as follows:

Category I – asbestos-containing packings, gaskets, resilient floor coverings, and asphalt roofing products.

Category II – all remaining types of nonfriable ACM not included in Category I that when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure.

Regulated asbestos-containing material (RACM), a California hazardous waste when friable, is classified as any manufactured material that contains greater than 1% asbestos by dry weight and is:

Friable; or

Category I material that has become friable; or

Category I material that has been subjected to sanding, grinding, cutting or abrading; or

Category II nonfriable material that has a high probability of becoming crumbled, pulverized, or reduced to a powder during demolition or renovation.

Activities that disturb materials containing any amount of asbestos are subject to certain requirements of the Cal/OSHA asbestos standard in Title 8, California Code of Regulations (CCR) §1529. Typically, removal or disturbance of more than 100 square feet of material containing more than 0.1% asbestos must be performed by a registered asbestos abatement contractor, but associated waste labeling is not required if the material contains 1% or less asbestos. When the asbestos content of a material exceeds

1%, virtually all requirements of the standard become effective.

Materials containing more than 1% asbestos are also subject to NESHAP regulations (40 CFR Part 61, Subpart M). RACM (friable ACM and nonfriable ACM that will become friable during demolition or renovation operations) must be removed from buildings prior to demolition or renovation. Contractors are responsible for segregating and characterizing waste streams prior to disposal.

With respect to potential worker exposure, notification, and registration requirements, Cal/OSHA defines asbestos-containing construction material (ACCM) as construction material that contains more than 0.1% asbestos (Title 8, CCR 341.6).

2.2 Lead

Construction activities (including demolition) that disturb materials or paints containing any amount of lead are subject to certain requirements of the Cal/OSHA lead standard in Title 8, CCR, §1532.1.

Deteriorated paint is defined by Title 17, CCR, Division 1, Chapter 8, §35022 as a surface coating that is cracking, chalking, flaking, chipping, peeling, non-intact, failed, or otherwise separating from a component. Demolition of a deteriorated LCP component would require waste characterization and appropriate disposal. Intact LCP on a component is currently accepted by most landfills and

Geocon Project No. S1544-03-38 - 3 - June 10, 2020 recycling facilities; however, contractors are responsible for segregating and characterizing waste streams prior to disposal.

For a solid waste containing lead, the waste is classified as California hazardous when: 1) the representative total lead content equals or exceeds the respective Total Threshold Limit

Concentration (TTLC) of 1,000 milligrams per kilogram (mg/kg); or 2) the representative soluble lead content equals or exceeds the respective Soluble Threshold Limit Concentration (STLC) of

5 milligrams per liter (mg/l) based on the standard Waste Extraction Test (WET). The soluble lead concentration of a waste has the potential to exceed the lead STLC when the waste’s representative total lead concentration is greater than or equal to 10 times the respective STLC value since the WET uses a 1:10 dilution ratio. Hence, when total lead is detected at a concentration greater than or equal to

50 mg/kg, and assuming that 100 percent of the total lead is soluble, soluble lead analysis is warranted.

Lead-containing waste is classified as “Resource, Conservation, and Recovery Act” (RCRA) hazardous, or Federal hazardous, when its soluble lead concentration equals or exceeds the Federal regulatory level of 5 mg/l based on the Toxicity Characteristic Leaching Procedure (TCLP).

The above regulatory criteria are based on chemical concentrations. Wastes may also be classified as hazardous based on other criteria such as ignitability; however, for the purposes of this investigation, toxicity (i.e., lead concentrations) is the primary factor considered for waste classification since waste generated during the construction activities would not likely warrant testing for ignitability or other criteria. Waste that is classified as either California hazardous or RCRA hazardous requires management as a hazardous waste.

Potential hazards exist to workers who remove or cut through LCP coatings during demolition. Dust containing hazardous concentrations of lead may be generated during scraping or cutting materials coated with lead-containing paint. Torching of these materials may produce lead oxide fumes.

Therefore, air monitoring and/or respiratory protection may be required during the demolition of materials coated with LCP. Guidelines regarding regulatory provisions for construction work where workers may be exposed to lead are in the Title 8, CCR, §1532.1.

2.3 PCBs

PCBs are man-made chemicals most commonly used as coolants, sealants, and lubricants. The use of

PCBs as insulation in electrical equipment was popular because PCBs are stable chemicals with low water solubility, high boiling points, low flammability, and low electrical conductivity. Prior to 1978, PCBs were used in the manufacturing of fluorescent lighting ballasts, transformers, capacitors, switches/breakers, circuitry, caulking compounds, plastics, adhesives, oil-based paints, hydraulic systems, and insulation (electrical and thermal). PCBs were produced in the United States from approximately 1929 to 1977. PCB production was banned under the Federal Toxic Substances Control

Act (TSCA) in 1978 due to evidence indicating that they accumulated in the environment and were

Geocon Project No. S1544-03-38 - 4 - June 10, 2020 linked to harmful health effects; however, the TSCA did not prohibit the installation or use of

PCB-containing items manufactured prior to the 1978 ban.

PCB wastes are regulated by the California Department of Toxic Substances Control (DTSC) and

RCRA. The DTSC has classified PCBs as a hazardous waste when total concentrations equal or exceed

50 mg/kg in solids, or 5 mg/l in liquids. If the PCB waste is greater than 50 mg/l, it must also be managed under RCRA requirements.

2.4 Universal Wastes

Universal wastes are common hazardous wastes generated by households and businesses and are generally not allowed to be disposed of in solid waste landfills. Universal wastes include such items as fluorescent light tubes and lamps (that may contain mercury), mercury-containing switches and thermostats, batteries, paints, oils, fuels, solvents, and electronic equipment.

Universal waste rules previously allowed these common, low-hazard wastes to be managed under less stringent requirements than hazardous wastes. California's Universal Waste Rule (CCR, Title 22, Division 4.5, Chapter 23), which is overseen by DTSC, became effective on February 8, 2002. Under the rule, universal wastes may not be discarded in municipal waste landfills. Previous regulatory exemptions that allowed households and other small quantity generators to dispose of some hazardous wastes in municipal solid waste landfills expired on February 9, 2006 (i.e., universal wastes may no longer be disposed of in municipal waste landfills). Additional suspect hazardous materials that may be present in buildings include such materials as PCBs in fluorescent light ballasts and chlorofluorocarbons (CFCs) in aerosols, air conditioning units, and refrigeration systems.

3.0 SCOPE OF SERVICES

Mr. David Watts completed the HAZMAT survey of the Site on May 1, 2020. Mr. Watts is a

California-Certified Asbestos Consultant (CAC), Certification No. 98-2404 (expiration

September 16, 2020), and Certified Lead Paint Inspector/Assessor and Project Monitor with the

California Department of Public Health (DPH), certification numbers 00002779 and 00002778

(expiration December 4, 2020). Mr. Watts has completed and passed the University of California at

Berkeley Management of PCBs in the Built Environment course and examination, respectively.

3.1 Asbestos

We grouped suspect ACM into homogeneous areas with representative samples randomly collected from each area. In addition, we evaluated each potential ACM for quantity and friability. We collected

93 bulk asbestos samples representing 44 material types at the Site.

Geocon Project No. S1544-03-38 - 5 - June 10, 2020

Our procedures for inspection and sampling included:

Collecting bulk asbestos samples after first wetting friable material with a mist of water. The samples were then cut from the substrate and transferred to labeled containers. Note that when multiple samples were collected, the sampling locations were distributed throughout the homogeneous area (spaces where the material was observed).

Relinquishing bulk asbestos samples under chain-of-custody protocol to EMSL Analytical, Inc.

(EMSL), a California-licensed laboratory, for asbestos analysis in accordance with Environmental Protection Agency (EPA) Test Method 600/R-93/116 using polarized light microscopy (PLM) procedures. EMSL is accredited by the National Institute of Standards and Technology National Voluntary Laboratory Accreditation Program (NIST-NVLAP) for bulk asbestos fiber analysis. The laboratory analyses were requested on a 120-hour turnaround time.

Sample locations are depicted on Figures 2A through 2C. Geocon sample group identification numbers, material descriptions, locations, approximate quantities, friability assessments, and photo references are summarized in Table 1. Materials represented by the samples collected are shown in the attached photographs.

3.2 Lead

We collected twenty-four bulk samples of suspect LCP and four bulk samples of ceramic tile during our survey. Mr. Watts field composited the paint samples into nine composite samples representing similar paint schemes. One ceramic tile sample (T-3A/B) was a 2-part composite sample representing a similar tile system. Our sampling procedures included:

Collecting representative bulk samples of suspect LCP using techniques presented in HUD guidelines.

In addition, each painted area was evaluated for evidence of deterioration such as flaking or cracking.

Relinquishing suspect LCP and ceramic tile samples under chain-of-custody protocol to Advanced Technology Laboratories (ATL), a California-licensed laboratory, for lead analyses in accordance with EPA Test Method 6010B. ATL is accredited by the DPH for lead analysis.

The laboratory analyses were requested on a 120-hour turnaround time.

Sample locations are depicted on Figures 2A through 2C. Geocon paint and ceramic tile sample identification numbers, descriptions, locations, and photo references are summarized in Table 2.

Materials represented by the samples collected are shown in the attached photographs.

3.3 PCBs

We collected three bulk samples of suspect PCB window putty during our survey. One sample (PCB-3A-C) was a 3-part composite sample representing a similar material. Our sampling procedures included:

Collecting representative bulk samples of suspect PCBs using techniques presented in the University of California at Berkeley Management of PCBs in the Built Environment course.

Relinquishing suspect samples under chain-of-custody protocol to ATL, a California-licensed laboratory, for PCB analyses in accordance with EPA Test Method 8082. ATL is accredited by the California State Environmental Laboratory Accreditation Program for PCB analysis. The laboratory analyses were requested on a 120-hour turnaround time.

Geocon Project No. S1544-03-38 - 6 - June 10, 2020

Sample locations are depicted on Figures 2A through 2C. Sample identification numbers, descriptions, locations, and photo references are summarized in Table 3. Materials represented by the samples collected are shown in the attached photographs.

3.4 Universal Wastes

Readily accessible items and equipment observed to represent potential universal wastes, or that may contain suspect hazardous materials on and in structures at the Site were inventoried. Equipment and items categorized as universal wastes or containing suspect hazardous materials, descriptions, locations, approximate quantities, and photo references are summarized in Table 4. Observed universal wastes and equipment containing suspect hazardous materials are shown in the attached photographs.

4.0 INVESTIGATIVE RESULTS

This section presents the results of field observations and laboratory analysis of samples for asbestos and lead content.

4.1 Asbestos

4.1.1 Building 104

Chrysotile asbestos at a concentration of 6% was detected in samples representing approximately

25 square feet of nonfriable asphalt roofing mastic.

Chrysotile and crocidolite asbestos at concentrations totaling 15% were detected in samples representing approximately 5 square feet of nonfriable 4-inch cementitious flue piping.

Chrysotile and crocidolite asbestos at concentrations totaling 12% were detected in samples representing approximately 10 square feet of nonfriable 6-inch (oval-shaped) cementitious flue piping.

Chrysotile asbestos at a concentration of 2% was detected in samples representing approximately

450 square feet of nonfriable beige vinyl floor tile (9 by 9-inch).

Chrysotile asbestos at a concentration less than (<) 1% was detected in samples representing approximately 250 square feet of nonfriable green vinyl floor tile (9 by 9-inch). This material is assumed to be ACM (i.e., greater than 1% asbestos).

Chrysotile asbestos at a concentration of 6% was detected in samples representing approximately

50 square feet of friable backing associated with orange resilient sheet flooring.

Geocon Project No. S1544-03-38 - 7 - June 10, 2020

Chrysotile asbestos at a concentration <0.25% was detected in samples representing approximately

3,200 square feet of gypsum board systems. The material (gypsum board/joint compound composite) was analyzed using PLM point counting methodology (400 points).

4.1.2 Building 103

Chrysotile asbestos at a concentration of 10% was detected in samples representing approximately

25 square feet of nonfriable asphalt roofing mastic.

3,800 square feet of gypsum board systems. The material (gypsum board/joint compound composite) was analyzed using PLM point counting methodology (400 points).

4.1.3 Building 101A/B

Chrysotile asbestos at a concentration of 10% was detected in samples representing approximately

2,500 square feet of nonfriable cementitious exterior wall panels.

4,500 square feet of gypsum board systems. The material (skim coat) was analyzed using PLM point counting methodology (400 points).

A summary of the analytical laboratory test results for asbestos is presented in Table 1. Reproductions of the laboratory reports and chain-of-custody documentation are presented in Appendix A.

4.2 Lead

4.2.1 Building 104

Our composite sample representing approximately 400 square feet of deteriorated gray exterior paint exhibited a representative total lead concentration of 56,000 mg/kg and a representative TCLP lead concentration of 140 mg/l.

Our composite sample representing approximately 50 square feet of deteriorated white exterior trim exhibited a representative total lead concentration of 110,000 mg/kg and a representative TCLP lead concentration of 160 mg/l.

Our composite sample representing approximately 20 square feet of deteriorated white interior paint exhibited a representative total lead concentration of 2,100 mg/kg and a representative TCLP lead concentration of 1.5 mg/l.

Geocon Project No. S1544-03-38 - 8 - June 10, 2020

Our sample representing approximately 80 square feet of intact gray ceramic tile exhibited a representative total lead concentration of 1.1 mg/kg.

4.2.2 Building 103

Our composite sample representing approximately 450 square feet of deteriorated white exterior paint exhibited a representative total lead concentration of 89,000 mg/kg and a representative TCLP lead concentration of 260 mg/l.

Our composite sample representing approximately 100 square feet of deteriorated beige exterior trim exhibited a representative total lead concentration of 130,000 mg/kg and a representative TCLP lead concentration of 210 mg/l.

Our composite sample representing approximately 10 square feet of deteriorated white interior paint exhibited a representative total lead concentration of 160 mg/kg. WET lead was not detected at or above the laboratory reporting limit (RL) of 1.0 mg/l.

Our sample representing approximately 80 square feet of intact white ceramic tile exhibited a representative total lead concentration of 4,900 mg/kg and a representative TCLP lead concentration of 4.2 mg/l.

4.2.3 Building 101A/B

Our composite sample representing approximately 750 square feet of deteriorated blue exterior paint exhibited a representative total lead concentration of 4,400 mg/kg and a representative TCLP lead concentration of 4.4 mg/l.

Our composite sample representing approximately 120 square feet of deteriorated white exterior trim exhibited a representative total lead concentration of 3,400 mg/kg and a representative TCLP lead concentration of 12 mg/l.

Our composite sample representing approximately 2 square feet of deteriorated white interior paint exhibited a representative total lead concentration of 5,400 mg/kg and a representative TCLP lead concentration of 3.5 mg/l.

Our composite sample representing approximately 160 square feet of intact yellow ceramic tile exhibited a representative total lead concentration of 3,300 mg/kg and a representative TCLP lead concentration of 0.65 mg/l.

A summary of the analytical laboratory test results for paint is presented in Table 2. Reproductions of the laboratory reports and chain-of-custody documentation are presented in Appendix A.

Geocon Project No. S1544-03-38 - 9 - June 10, 2020

4.3 PCBs

PCBs were not detected at or above the laboratory RL of 16 micrograms per kilogram (µg/kg) in samples of suspect materials collected during our survey.

A summary of the analytical laboratory test results for PCBs is presented in Table 3. Reproductions of the laboratory reports and chain-of-custody documentation are presented in Appendix A.

4.4 Universal Wastes

4.4.1 Building 104

Four fluorescent lighting fixtures were observed. Three air conditioning units, one thermostat, one smoke alarm, and various household chemicals (lubricants, solvents, cleansers, paints, fire extinguishers, etc.) were observed.

4.4.2 Building 103

Twelve fluorescent lighting fixtures were observed. One air conditioning unit, two thermostats, two smoke alarms, and various household chemicals (lubricants, solvents, cleansers, paints, fire extinguishers, etc.) were observed.

4.4.3 Building 101A/B

Twenty-three fluorescent lighting fixtures were observed. Two air conditioning units, two thermostats, two smoke alarms, and various household chemicals (lubricants, solvents, cleansers, paints, fire extinguishers, etc.) were observed.

An inventory of observed universal wastes and suspect hazardous materials is presented in Table 4.

5.0 CONCLUSIONS AND RECOMMENDATIONS

5.1 Asbestos

5.1.1 Building 104

NESHAP regulations require that cementitious flue piping (a Category II nonfriable/nonhazardous material) and backing associated with resilient sheet flooring (a friable RACM) be removed prior to disturbance activities associated with renovation or demolition.

NESHAP regulations do not require that asbestos-containing roofing mastic and floor tile (Category I nonfriable/nonhazardous materials) or materials containing 1% or less asbestos (i.e., gypsum board systems) identified during our survey be removed prior to disturbance activities associated with renovation or

Geocon Project No. S1544-03-38 - 10 - June 10, 2020 demolition. However, the disturbance of these materials is still covered by the Cal/OSHA asbestos standard (Title 8, CCR §1529). We recommend that a licensed contractor who is registered with Cal/OSHA for asbestos-related work perform disturbance activities associated with renovation or demolition.

We also recommend the notification of contractors (that may be conducting renovation, demolition, or related activities) and building occupants of the presence of asbestos in their work areas (i.e., provide the contractor[s] and building occupants with a copy of this report and a list of asbestos removed by contractor[s] during subsequent activities). Personnel not trained for asbestos work should be instructed not to disturb asbestos.

5.1.2 Building 103

NESHAP regulations do not require that asbestos-containing roofing mastic (a Category I nonfriable/nonhazardous material) or materials containing 1% or less asbestos (i.e., gypsum board systems) identified during our survey be removed prior to disturbance activities associated with renovation or demolition. However, the disturbance of these materials is still covered by the Cal/OSHA asbestos standard

(Title 8, CCR §1529). We recommend that a licensed contractor who is registered with Cal/OSHA for asbestos-related work perform disturbance activities associated with renovation or demolition.

related activities) and building occupants of the presence of asbestos in their work areas (i.e., provide the contractor[s] and building occupants with a copy of this report and a list of asbestos removed by contractor[s] during subsequent activities). Personnel not trained for asbestos work should be instructed

5.1.3 Building 101A/B

NESHAP regulations require that cementitious wall panels (a Category II nonfriable/nonhazardous material) be removed prior to disturbance activities associated with renovation or demolition.

NESHAP regulations do not require that materials containing 1% or less asbestos (i.e., gypsum board systems) identified during our survey be removed prior to disturbance activities associated with renovation or demolition. However, the disturbance of these materials is still covered by the Cal/OSHA asbestos standard (Title 8, CCR §1529). We recommend that a licensed contractor who is registered with Cal/OSHA for asbestos-related work perform disturbance activities associated with renovation or demolition.

related activities) and building occupants of the presence of asbestos in their work areas (i.e., provide the contractor[s] and building occupants with a copy of this report and a list of asbestos removed by contractor[s] during subsequent activities). Personnel not trained for asbestos work should be instructed

Geocon Project No. S1544-03-38 - 11 - June 10, 2020

Written notification to the San Joaquin Valley Air Pollution Control District is required ten working days prior to: 1) commencement of renovation activities disturbing 160 square feet or more of building materials; or 2) any demolition activity (whether asbestos is present or not). In accordance with Title 8, CCR 341.9, written notification to the nearest Cal/OSHA district office is required at least 24 hours prior to certain asbestos-related work

5.2 Lead

5.2.1 Building 104

Deteriorated paints identified during our survey would be classified as California hazardous based on lead content. Deteriorated exterior paints would also be classified as Federal hazardous based on lead content. As such, deteriorated LCP must be removed and disposed of prior to disturbance activities associated with renovation or demolition.

Notification to Cal/OSHA for lead work is required for activities disturbing exterior LCP identified during our survey.

5.2.2 Building 103

Deteriorated exterior paints identified during our survey would be classified as California and Federal hazardous based on lead content. As such, deteriorated exterior LCP must be removed and disposed of prior to disturbance activities associated with renovation or demolition.

Ceramic tile identified during our survey would be classified as California hazardous based on lead content. As such, the tile must be removed and disposed of prior to disturbance activities associated with renovation or demolition.

Notification to Cal/OSHA for lead work is required for activities disturbing exterior LCP identified during our survey.

5.2.3 Building 101A/B

Deteriorated paints identified during our survey would be classified as California hazardous based on lead content. Deteriorated white exterior trim would also be classified as Federal hazardous based on lead content. As such, deteriorated LCP must be removed and disposed of prior to disturbance activities associated with renovation or demolition.

Ceramic tile identified during our survey would be classified as California hazardous based on lead content. As such, the tile must be removed and disposed of prior to disturbance activities associated with renovation or demolition.

Geocon Project No. S1544-03-38 - 12 - June 10, 2020

Notification to Cal/OSHA for lead work is not required for activities disturbing lead-containing materials identified during our survey.

Contractors removing LCP should be required to use personnel who have lead-related construction certification as supervisors or workers, as appropriate, from the California DPH for LCP removal work.

Deteriorated/stripped LCP requires waste segregation to separate hazardous waste (Category III concentrated lead such as loose paint, paint sludge, vacuum debris, and vacuum filters) from non-hazardous demolition debris (Category II intact lead-painted architectural components). Category I waste is low lead waste (typically non-hazardous) such as construction materials, filtered wash water, and plastic sheeting. Contractors are responsible for informing the landfill of the contractor’s intent to dispose of RCRA waste, California hazardous waste, and/or architectural components containing intact

LCP. Landfills and recycling facilities may require additional waste characterization. Contractors are responsible for segregating and characterizing waste streams prior to disposal.

We recommend that all paints at the project locations be treated as lead-containing for purposes of determining the applicability of the Cal/OSHA lead standard during maintenance, renovation, and demolition activities. This recommendation is based on LCP sample results and the fact that lead was a common ingredient of paints manufactured before 1978 and is still an ingredient of some paints.

Compliance and training requirements regarding construction activities where workers may be exposed to lead are presented in Title 8, CCR, § 1532.1, subsections (e) and (l), respectively.

5.3 PCBs

Since PCBs were not detected, activities disturbing materials represented by samples collected during our survey would not be subject to Cal/OSHA PCB regulation. In addition, associated debris would not be considered a California or Federal hazardous waste based on PCB content.

5.4 Universal Wastes

Fluorescent light tubes should be removed and managed for recycling. Light ballasts should be inspected for PCB status (e.g., labeling) prior to disposal; light ballasts that are unlabeled, or lacking a

“No PCB’s” designation on their labels, should be removed from light fixtures and managed as a hazardous waste.

Fuels, CFCs, flammable materials (solvents, paints, etc.), fire extinguishers, and suspect metals

(thermostats and smoke alarms) should be removed from the Site for recycling or disposal by contractors licensed to handle, transport, and/or dispose of universal wastes and hazardous wastes.

Geocon Project No. S1544-03-38 - 13 - June 10, 2020

6.0 REPORT LIMITATIONS

This report has been prepared exclusively for DGS. The information contained herein is valid as of the date of the report and will require an update to reflect additional information obtained.

Our HAZMAT survey was conducted in conformance with generally accepted standards of practice for identifying and evaluating hazardous materials in structures. The survey addressed only the structures identified in Section 1.1. Due to the nature of structure surveys, hazardous materials use, and laboratory analytical limitations, some hazardous materials in the structures may not have been identified. Spaces, such as cavities, crawlspaces, voids, and pipe chases, may have been concealed to our investigator. Previous retrofit/rehabilitation work may have concealed or covered spaces or materials, or may have partially demolished materials and left debris in inaccessible areas.

Additionally, retrofit/rehabilitation activities may have partially replaced hazardous materials with indistinguishable materials. Hazardous materials may exist in areas not accessible or sampled in conjunction with our scope of services.

During renovation or demolition operations, suspect materials may be uncovered which are different from those accessible for sampling during this assessment. Personnel in charge of renovation/demolition should be alerted to note materials uncovered during such activities that differ substantially from those included in this or previous assessment reports. If additional suspect materials are found, they should be treated as hazardous until/unless sampling and analysis indicate otherwise.

This report is not a comprehensive site characterization and should not be construed as such. The findings as presented in this report are predicated on the results of the limited sampling and laboratory testing performed. In addition, the information obtained is not intended to address potential impacts related to sources other than those specified herein. Therefore, the report should be deemed conclusive with respect to only the information obtained. We make no warranty with respect to the content of this report or subsequent reports, correspondence, or consultation. Geocon strived to perform the services summarized herein in accordance with the local standard of care in the geographic region at the time the services were rendered.

The contents of this report reflect the views of the author who is responsible for the facts and accuracy of the data presented herein. This report does not constitute a standard, specification, or regulation.

Porterville, California

Developmental Training Activity Center-

GEOCON Proj. No. S1544-03-38

APPROX. SCALE: miles

0 3

3160 GOLD VALLEY DR – SUITE 800 – RANCHO CORDOVA, CA 95742 - PHONE 916.852.9118

VICINITY MAP

June 2020 Figure 1

26501 Avenue 140, PROJECT LOCATION

Tulare Lindsay HwyTULARE

TIPTON

WOODVILLE

STRATHMORE

LINDSAY

W Poplar Ave E Poplar Ave

PORTERVILLE

S Ma in St

Ave. 140

Lake Success

Buildings 104, 103, & 101A/B

AutoCAD SHX Text

SITE0520.DWG

APPROX. SCALE: feet

0 105

LEGEND:

Approximate Asbestos Sample Location

Approximate Ceramic Tile Sample Location

Roof(R) Porterville, California

Developmental Training Activity Center-

GEOCON Proj. No. S1544-03-38

3160 GOLD VALLEY DR – SUITE 800 – RANCHO CORDOVA, CA 95742 - PHONE 916.852.9118

SITE PLAN

June 2020 Figure 2A

26501 Avenue 140, Building 104

Approximate PCB Sample Location

2C

13BP1C

3A

PCB-1

P2A 5A(R)

2B P1B 3B 1B

9A/B(R) 4A P2B

16B 17B 14B

6A(R)

2A

P1A

P2CP3B

17A

11B

1A

11A

7A/B(R)

8A/B(R) P3A10A(R)

10B(R)

4B(R)

6B(R)

5B(R) 16A

12B 17C

14A 12A

13A T-1

15A/B 00A/B

Approximate Paint Sample Location T P

GEOCON Proj. No. S1544-03-38

3160 GOLD VALLEY DR – SUITE 800 – RANCHO CORDOVA, CA 95742 - PHONE 916.852.9118

SITE PLAN

June 2020 Figure 2B

26501 Avenue 140, Building 103

19A

29B

22A(R)28A

20B

P4A

P5C

31C

19C

P4B

PCB-2

P5B 30A/B

T-2

23A(R) 32A/B 27B

25A(R)

18B 29A

31B 21B(R) 21A

24A/B(R)

28B 22B(R)

20A

P4C P5A

19B

26B

P6B31AP6A

26A

18A

27A23B(R)25B(R)

APPROX. SCALE: feet

0 105

LEGEND:

Approximate Asbestos Sample Location

Approximate Ceramic Tile Sample Location

Roof(R) Approximate PCB Sample Location

Approximate Paint Sample Location T P

GEOCON Proj. No. S1544-03-38

3160 GOLD VALLEY DR – SUITE 800 – RANCHO CORDOVA, CA 95742 - PHONE 916.852.9118

SITE PLAN

June 2020 Figure 2C

26501 Avenue 140, Building 101A/B

33B

P9A

41A

44A (Attic) 42A

40A

T-3A

43A

39A

35B

34A

PCB-3A

P7C

36A(R)

P8A

P7A

P8C 37B(R)

38A(R)

PCB-3B

36B(R)

42B

P9B

PCB-3C

35A 39B

34B

P8B

P7B

33A

41B44B (Attic)

38B(R) 42C40B

43B T-3B

37A(R)

APPROX. SCALE: feet

0 105

LEGEND:

Approximate Asbestos Sample Location

Approximate Ceramic Tile Sample Location

Roof(R) Approximate PCB Sample Location

Approximate Paint Sample Location T P

Photo 1 – Building 104 (a 2-bedroom unit)

Photo 2 – Building 104 exterior

Photo 3 – Building 104 roof (roofing mastic is asbestos-containing)

PHOTOGRAPHS 1, 2, & 3

Buildings 104, 103, and 101A/B

Porterville Development Center at 26501 Avenue 140 Porterville, Tulare County, California

S1544-03-38 June 2020

Photo 4 – Building 104 roof (flue in foreground is asbestos cement)

Photo 5 – Building 104 roof

Photo 6 – Building 104 roof (flue in foreground is asbestos cement)

PHOTOGRAPHS 4, 5, & 6

Buildings 104, 103, and 101A/B

Porterville Development Center at 26501 Avenue 140

Photo 7 – Building 104 living room (asbestos floor tile)

Photo 8 – Building 104 bedroom (asbestos floor tile beneath carpet pad)

Photo 9 – Building 104 bath (asbestos sheet flooring)

PHOTOGRAPHS 7, 8, & 9

Buildings 104, 103, and 101A/B

Porterville Development Center at 26501 Avenue 140

Photo 10 – Building 104 bath

Photo 11 – Building 104 kitchen (asbestos floor tile)

Photo 12 – Building 104 garage

PHOTOGRAPHS 10, 11, & 12

Buildings 104, 103, and 101A/B

Porterville Development Center at 26501 Avenue 140

Photo 13 – Building 104 kitchen

Photo 14 – Building 104 entry

Photo 15 – Building 104 thermostat

PHOTOGRAPHS 13, 14, & 15

Buildings 104, 103, and 101A/B

Porterville Development Center at 26501 Avenue 140

Photo 16 – Building 104 bedroom

Photo 17 – Building 104 kitchen

Photo 18 – Building 104 street view

PHOTOGRAPHS 16, 17, & 18

Buildings 104, 103, and 101A/B

Porterville Development Center at 26501 Avenue 140

Photo 19 – Building 103 (a 3-bedroom unit)

Photo 20 – Building 103 exterior

Photo 21 – Building 103 roof (roofing mastic is asbestos-containing)

PHOTOGRAPHS 19, 20, & 21

Buildings 104, 103, and 101A/B

Porterville Development Center at 26501 Avenue 140

Photo 22 – Building 103 roof (metal flues)

Photo 23 – Building 103 roof

Photo 24 – Building 103 living room

PHOTOGRAPHS 22, 23, & 24

Buildings 104, 103, and 101A/B

Porterville Development Center at 26501 Avenue 140

Photo 25 – Building 103 kitchen

Photo 26 – Building 103 bedroom

Photo 27 – Building 103 bedroom closet

PHOTOGRAPHS 25, 26, & 27

Buildings 104, 103, and 101A/B

Porterville Development Center at 26501 Avenue 140

Photo 28 – Building 103 bath

Photo 29 – Building 103 garage

Photo 30 – Building 103 garage

PHOTOGRAPHS 28, 29, & 30

Buildings 104, 103, and 101A/B

Porterville Development Center at 26501 Avenue 140

Photo 31 – Building 103 kitchen

Photo 32 – Building 103 kitchen

Photo 33 – Building 103 living room

PHOTOGRAPHS 31, 32, & 33

Buildings 104, 103, and 101A/B

Porterville Development Center at 26501 Avenue 140

Photo 34 – Building 103 bedroom closet

Photo 35 – Building 103 hallway

Photo 36 – Building 103 street view

PHOTOGRAPHS 34, 35, & 36

Buildings 104, 103, and 101A/B

Porterville Development Center at 26501 Avenue 140

Photo 37 – Building 101A/B street view (a duplex unit)

Photo 38 – Building 101A exterior (panels are asbestos-containing)

Photo 39 – Building 101B exterior (panels are asbestos-containing)

PHOTOGRAPHS 37, 38, & 39

Buildings 104, 103, and 101A/B

Porterville Development Center at 26501 Avenue 140

Photo 40 – Building 101A/B roof

Photo 41 – Building 101A living room and dining area

Photo 42 – Building 101A kitchen and dining area

PHOTOGRAPHS 40, 41, & 42

Buildings 104, 103, and 101A/B

Porterville Development Center at 26501 Avenue 140

Photo 43 – Building 101A bath

Photo 44 – Building 101A ceiling cavity

Photo 45 – Building 101A bedroom

PHOTOGRAPHS 43, 44, & 45

Buildings 104, 103, and 101A/B

Porterville Development Center at 26501 Avenue 140

Photo 46 – Building 101A hallway

Photo 47 – Building 101A living room

Photo 48 – Building 101A kitchen

PHOTOGRAPHS 46, 47, & 48

Buildings 104, 103, and 101A/B

Porterville Development Center at 26501 Avenue 140

Photo 49 – Building 101A/B carport storage area

Photo 50 – Building 101A/B laundry room

Photo 51 – Building 101A/B carport storage area

PHOTOGRAPHS 49, 50, & 51

Buildings 104, 103, and 101A/B

Porterville Development Center at 26501 Avenue 140

Photo 52 – Building 101B conference room

Photo 53 – Building 101B office

Photo 54 – Building 101B bath

PHOTOGRAPHS 52, 53, & 54

Buildings 104, 103, and 101A/B

Porterville Development Center at 26501 Avenue 140

Photo 55 – Building 101B kitchen

Photo 56 – Building 101B ceiling cavity

Photo 57 – Building 101B conference room

PHOTOGRAPHS 55, 56, & 57

Buildings 104, 103, and 101A/B

Porterville Development Center at 26501 Avenue 140

Photo 58 – Building 101B conference room

Photo 59 – Building 101B hallway

Photo 60 – Building 101B kitchen

PHOTOGRAPHS 58, 59, & 60

Buildings 104, 103, and 101A/B

Porterville Development Center at 26501 Avenue 140

Geocon Project No. S1544-03-38 June 2020

Sample Group Material Description Location Approximate Quantity Friable Site Photos Asbestos Content EPA Category

Building 104 (2-Bedroom) 1 Concrete Throughout NA NA 1 and 12 ND NA 2 Stucco Exterior walls NA NA 1, 2, and 18 ND NA 3 Window putty Windows NA NA 2 ND NA 4 Block/mortar Chimney and fireplace NA NA 1, 5, and 7 ND NA 5 Asphalt roofing core (roll) Roof NA NA 3 through 6 ND NA 6 Asphalt roofing mastic Roof 25 square feet No 3 through 6 6% I 7 Cementitious flue (4-inch) Roof 5 square feet No 4 15% II 8 Cementitious flue (6-inch, oval) Roof 10 square feet No 6 12% II 9 Cementitious flue (12-inch, oval) Roof NA NA 5 ND NA

10 Duct sealant Roof NA NA 3 and 4 ND NA 11 Vapor barrier Throughout NA NA 12 ND NA 12 Beige, 12 by 12-inch floor tile system Living room NA NA 7 ND NA 13 Beige, 9 by 9-inch floor tile system Bedroom 450 square feet No 8 2% (tile) I 14 Green, 9 by 9-inch floor tile system Kitchen and bedroom closet 250 square feet No 11 >1% (tile, assumed) I 15 Orange, resilient sheet flooring Bath 50 square feet Yes 9 6% (backing) RACM 16 Base coving Throughout NA NA 7 and 9 ND NA 17 Gypsum board system Throughout 3,200 square feet NA 7 through 17 <0.25%* NA 00 Gray, ceramic tile system Bath NA NA 10 ND NA

Building 103 (3-Bedroom) 18 Concrete Throughout NA NA 19 and 29 ND NA 19 Stucco Exterior walls NA NA 19, 20, and 36 ND NA 20 Window putty Windows NA NA 20 ND NA 21 Block/mortar Chimney and fireplace NA NA 21, 23, and 24 ND NA 22 Asphalt roofing core (roll) Roof NA NA 21 through 23 ND NA 23 Asphalt roofing mastic Roof 25 square feet No 21 through 23 6% I 24 Cementitious flue (12-inch, oval) Roof NA NA 23 ND NA 25 Duct sealant Roof NA NA 21 ND NA 26 Vapor barrier Throughout NA NA 29 ND NA 27 Beige, resilient sheet flooring Kitchen and bath NA NA 25 and 28 ND NA 28 Carpet mastic Living room and bedrooms NA NA 26 ND NA 29 Base coving Throughout NA NA 24 through 28 ND NA 30 White, 12 by 12-inch floor tile system Bedroom closet NA NA 27 ND NA

Polarized Light Microscopy (PLM) - EPA Test Method 660/R-93/116

TABLE 1

SUMMARY OF ANALYTICAL LABORATORY RESULTS - ASBESTOS

26501 AVENUE 140, PORTERVILLE, CALIFORNIA

DEVELOPMENTAL TRAINING ACTIVITY CENTER – BUILDINGS 104, 103, & 101A/B

Sample Group Material Description Location Approximate Quantity Friable Site Photos Asbestos Content EPA Category

Polarized Light Microscopy (PLM) - EPA Test Method 660/R-93/116

TABLE 1

SUMMARY OF ANALYTICAL LABORATORY RESULTS - ASBESTOS

26501 AVENUE 140, PORTERVILLE, CALIFORNIA

DEVELOPMENTAL TRAINING ACTIVITY CENTER – BUILDINGS 104, 103, & 101A/B

Building 103 (continued) 31 Gypsum board system Throughout 3,800 square feet NA 24 through 35 <0.25%* NA 32 White, ceramic tile system Bath NA NA 28 ND NA

Building 101A/B (Duplex) 33 Concrete Throughout NA NA 37 and 38 ND NA 34 Cementitious panels Exterior walls 2,500 square feet No 37 through 39 10% II 35 Window putty Windows NA NA 38 and 39 ND NA 36 Asphalt roofing core (tile) Roof NA NA 40 ND NA 37 Asphalt roofing core (roll) Roof NA NA 40 ND NA 38 Asphalt roofing mastic Roof NA NA 40 ND NA 39 Vapor barrier Throughout NA NA 51 ND NA 40 Gray, resilient sheet flooring Throughout NA NA 42 and 52 ND NA 41 Base coving Throughout NA NA 41 and 59 ND NA 42 Gypsum board system Throughout 4,500 square feet NA 41 and 57 <0.25%** NA 43 Yellow, ceramic tile system Baths NA NA 43 and 54 ND NA 44 Blown-in insulation Attics and ceiling cavities NA NA 44 and 56 ND NA

Notes:

EPA = United States Environmental Protection Agency NA = NA = Not applicable ND = Asbestos fibers not detected

RACM = Regulated Asbestos-Containing Material

* Gypsum board and joint compound composite result; analyzed using PLM Point Counting (400 points)

** Skim coat result; analyzed using PLM Point Counting (400 points)

Sample No. Description Location Approximate Quantity

Peeling/Flaking Site Photos Total Lead

(mg/kg) WET Lead

(mg/l) TCLP Lead

(mg/l)

Building 104 (2-Bedroom) P1A-C Gray exterior paint Exterior walls 400 square feet 1, 2, and 18 56,000 --- 140 P2A-C White exterior trim Exterior trim 50 square feet 1, 2, and 18 110,000 --- 160 P3A/B White interior paint Kitchen 20 square feet 17 2,100 --- 1.5

T1 Gray, ceramic tile system Bath Intact 10 1.1 --- ---

Building 103 (3-Bedroom) P4A-C White exterior paint Exterior walls 450 square feet 19, 20, and 36 89,000 --- 260 P5A-C Beige exterior trim Exterior trim 100 square feet 19, 20, and 36 130,000 --- 210 P6A/B White interior paint Garage 10 square feet 30 160 <1.0 ---

T2 White, ceramic tile system Bath Intact 28 4,900 --- 4.2

Building 101A/B (Duplex) P7A-C Blue exterior paint Exterior walls 750 square feet 37, 38, and 39 4,400 --- 4.4 P8A-C White exterior trim Exterior trim 120 square feet 37, 38, and 39 3,400 --- 12 P9A/B White interior paint 101B Kitchen 2 square feet 55 5,400 --- 3.5 T3A/B Yellow, ceramic tile system Baths Intact 43 and 54 3,300 --- 0.65 Notes:

mg/kg = milligrams per kilogram (EPA Test Method 6010B) WET = Waste Extraction Test mg/l = milligrams per liter (EPA Test Method 6010B)

TCLP = Toxicity Characteristic Leaching Procedure --- = not analyzed

< = not detected at or above the indicated laboratory reporting limit

DEVELOPMENTAL TRAINING ACTIVITY CENTER – BUILDINGS 104, 103, & 101A/B

Total and Soluble Lead

TABLE 2

SUMMARY OF ANALYTICAL LABORATORY RESULTS - PAINT AND CERAMIC TILE

Sample No. Description Site Photos Aroclors 1016 through 1268 (µg/kg)

PCB-1 Window putty (Building 104, 2-bedroom) 2 <16

PCB-2 Window putty (Building 103, 3-bedroom) 20 <16

PCB-3A-C Window putty (Building 101A/B, duplex) 38 and 39 <16

Notes:

µg/kg = micrograms per kilogram

< = not detected at or above the indicated laboratory reporting limit

DEVELOPMENTAL TRAINING ACTIVITY CENTER – BUILDINGS 104, 103, & 101A/B

Polychlorinated Biphenyls (PCBs) by EPA 8082

TABLE 3

SUMMARY OF ANALYTICAL LABORATORY RESULTS - POLYCHLORINATED BIPHENYLS

TABLE 4

UNIVERSAL WASTES

DEVELOPMENTAL TRAINING ACTIVITY CENTER – BUILDINGS 104, 103, & 101A/B

26501 AVENUE 140, PORTERVILLE, CALIFORNIA

Component Description Suspect Hazardous Constituent Locations Site Photos Approximate Quantities

Building 104 (2-Bedroom) Fluorescent lighting fixtures Mercury (lighting tubes)/PCBs (ballasts) Throughout structure 13 4

Air conditioning units CFCs Roof and bedrooms 3 and 16 3

Various household chemicals Lubricants, solvents, cleansers, paints, fire extinguishers, etc.

Throughout structure 14 Various

Thermostsats/smoke alarms Metals Living room/hallway 15 1 each

Building 103 (3-Bedroom) Fluorescent lighting fixtures Mercury (lighting tubes)/PCBs (ballasts) Throughout structure 31 and 34 12

Air conditioning units CFCs Roof 21 1

Various household chemicals Lubricants, solvents, cleansers, paints, fire extinguishers, etc.

Throughout structure 32 Various

Thermostsats/smoke alarms Metals Kitchen/living room/hallway 33 and 35 2 each

Building 101A/B (Duplex) Fluorescent lighting fixtures Mercury (lighting tubes)/PCBs (ballasts) Throughout structure 41, 45, 46, 52, 53, and 57 10 (103A) and 13 (103B)

Air conditioning units CFCs Roof 40 1 each (103A and 103B)

Various household chemicals Lubricants, solvents, cleansers, paints, fire extinguishers, etc.

Throughout structure 47, 48, 50, and 60 Various

Thermostsats/smoke alarms Metals Living room/hallway 46, 58, and 59 1 each (103A and 103B)

Notes:

PCBs = Polychlorinated biphenyls CFCs = Chlorofluorocarbons (refrigerants, aerosols, etc.)

APPENDIX A

APPENDIX B

EMSL Analytical, Inc.

464 McCormick Street San Leandro, CA 94577

Tel/Fax: (510) 895-3675 / (510) 895-3680 http://www.EMSL.com / sanleandrolab@emsl.com

092007838EMSL Order:

Customer ID: GECN21

Customer PO: S1544-03-38

Project ID: S1544-03-**

Attention: Phone:Dave Watts (925) 785-5340

Fax:Geocon Consultants, Inc. (925) 371-5915

Received Date:6671 Brisa Street 05/05/2020 10:00 AM

Analysis Date:Livermore, CA 94550 05/12/2020

Collected Date: 04/30/2020

Project: S1544-03-38 - PORTERVILLE DEV CTR (S1544-03-**)

Test Report: Asbestos Analysis of Bulk Materials via EPA 600/R-93/116 Method…