A2-9_HAZMAT_Phase_II_Report.pdf

EnviroScience, Inc.

An Environmental Consulting and Industrial Hygiene Company

2220 S. Bascom Avenue • Campbell, California 95008 • (408) 371-4181 • Fax (408) 371-4186

100% SUBMITTAL

REPORT FOR

PCB, MERCURY VAPOR,

ASBESTOS & LEAD PAINT INSPECTION

AND SAMPLING

Name of Facility:

MOTCO

Concord, California

Surveyed Areas:

Pier 2, Building A21 & Building 100

Inspection Dates:

July 27, 2015

Name & License of the Inspecting & Reporting Officials:

Hooman Sotoodeh, Ph.D., PE Alfredo Rocha III, SST

Cal/OSHA-Certified Asbestos Consultant (Nº 93-1097) Cal/OSHA-Certified Site Surveillance Tech. (Nº 00-2806) CDPH-Certified Lead Inspector/Assessor (Nº 1820) CDPH-Certified Lead Sampling Technician (Nº 20474)

H. Sotoodeh A. Rocha Hooman Sotoodeh, Ph.D., PE Alfredo Rocha, III

Report Date September 15, 2015

ESI Project #066-15-11

100% Submittal

Report for PCB, Mercury Vapor, Asbestos & Lead Paint Inspection & Sampling at Page 2 MOTCO — Pier 2, Building A21 & Building 100 — Concord, California EnviroScience, Inc.

CONTENTS

SECTION DESCRIPTION PAGE

A. Background

B. Field Investigation

C. Equipment, Tools and Instruments

D. Inspection Summary

E. Regulations

F. Recommendations for Abatement

G. Requirements for Air Monitoring During Friable Asbestos Abatement

H. Limitations

I. Summary Tables Table 1 —ACMs Table 2 —LCPs Table 3 —PCBs Table 4 —Fluorescent Light Tubes Table 5 —Freon Gas

J. Site Plan of the MOTCO — Pier 2

K. Asbestos & Lead Sample Locations — Building A21 Showing Sample Locations

L. Analysis and Test Results for Asbestos Samples by the Independent Laboratory

M. Analysis and Test Results for Lead Samples by the Independent Laboratory

Report for PCB, Mercury Vapor, Asbestos & Lead Paint Inspection & Sampling at Page 3 MOTCO — Pier 2, Building A21 & Building 100 — Concord, California EnviroScience, Inc.

A. BACKGROUND

EnviroScience, Inc. (ESI) has completed a facility inspection and sampling to identify suspect hazardous materials on Pier 2, in Building A21, and Portable Building 100 at MOTCO in Concord, CA. Building 160, which was also part of the survey, was already demolished by others at the time of ESI’s Site visit on July 27, 2015.

The purpose of ESI’s survey was to identify, sample, and inventory the hazardous materials (listed in the following section), for proper removal and abatement prior to demolition.

ESI's services were requested by Mr. Ronald F. Muller, PE, Senior Consultant for GEI Consultants, Inc., of Rancho Cordova, California.

The Site inspection and field sampling was conducted on July 27, 2015, by Mr. Hooman Sotoodeh, Ph.D., P.E., Cal/OSHA-certified asbestos consultant (CAC #93-1095), and CDPH-Certified Lead Inspector/Assessor (#1820), accompanied by Mr. J. Stephen Volk, Environmental Compliance Manager for MOTCO Department of Public Works.

Report for PCB, Mercury Vapor, Asbestos & Lead Paint Inspection & Sampling at Page 4 MOTCO — Pier 2, Building A21 & Building 100 — Concord, California EnviroScience, Inc.

B. FIELD INVESTIGATION

After a detailed review of the Phase Environmental Site Assessment (ESA) report prepared by UEG, dated December 18, 2014, a preliminary Site inspection by ESI’s field inspector, and interview with Mr. J. Stephen Volk, Environmental Compliance Manager for MOTCO Department of Public Works who accompanied ESI during the Site inspection & sampling, ESI’s field inspector identified the following construction materials as suspect hazardous materials, requiring further testing or characterization:

• Asbestos-containing materials (ACMs) in the form of thermal system insulations

(TSI), surfacing, and miscellaneous materials;

• Lead-containing paints (LCPs) on various interior and exterior surfaces;

• PCB oil (assumed) inside fluorescent light ballasts & inside 3 electrical transformers in Building A21; and

• Mercury vapor tubes (assumed) inside fluorescent light fixtures & metal halide exterior lights.

To further characterize the suspect hazardous materials identified above, ESI collected a total of 27 sample layers of suspect ACMs, and 10 samples of suspect LCPs from the Pier, and two structures (A21 & Portable Building 100).

Due to the age of the Pier and the 2 existing structures, ESI’s Sr. Industrial Hygienist (IH) assumed that all fluorescent light ballasts & electrical transformers contained Polychlorinated Biphenyls (PCBs), and that all fluorescent light tubes and metal halide bulbs contained mercury or other hazardous vapors.

In general the following building materials were sampled and analyzed for asbestos content:

1. Various sizes and colors of vinyl floor tiles and associated mastics

2. Mastic behind vinyl base coves (baseboards)

3. Wallboard joint compounds & skim coats

4. Textured wall skim coat

5. Wall plaster

6. Thermal system insulation (straight run pipes, elbows, and tank insulation)

7. Caulkings & mastics along exterior siding, roof & sprinkler pipes

8. Roofing material

The following painted surfaces were analyzed for total lead concentration:

1. Interior and exterior wall surfaces (various rooms & colors)

2. Interior metal door frames

3. Exterior paint on siding

4. Exterior paint on gutters and downspouts

5. Exterior paint on sprinkler pipes

The main intent of ESI’s survey was to compile an inventory of hazardous materials as identified by the Resource Conservation and Recovery Act (RCRA) 42 U.S.C. §§ 6901 to 6991I., to be properly abated and disposed of prior to demolition of the two structures.

Report for PCB, Mercury Vapor, Asbestos & Lead Paint Inspection & Sampling at Page 5 MOTCO — Pier 2, Building A21 & Building 100 — Concord, California EnviroScience, Inc.

In general, ESI’s field survey involved the following four tasks:

Task 1–Initial Facility Walk-Through To study the structure of the two buildings on Site, narrow down the scope of the survey, and identify the sampling strategy, ESI's on-site inspector conducted an initial facility walk-through with the Client’s representative.

From this walk-through a number of locations were identified as potential areas for use of ACMs, LCPs, PCBs, and mercury or other gases. ESI's inspector then developed a sampling strategy for testing or quantifying suspect hazardous materials.

Materials such as fluorescent light ballasts & electrical transformers were assumed to contain PCBs, and fluorescent light tubes & metal halide light bulbs were assumed to contain mercury or other gases, based on the age of the structure and the intrinsic nature of these types of materials or components.

Task 2–Defining Homogeneous Sampling Areas A homogeneous sampling area is one that is uniform in color, texture, or date of application.

Each separate type of suspect material was considered a separate homogeneous material.

For example, floor tile of the same size and color, or wall paint of the same color and texture that was consistent throughout an entire area or room was considered one homogeneous sampling area, and sampled only once.

Task 3–Sample Collection Once the homogeneous sampling areas were identified, then the suspect material was either sampled or considered to be hazardous based on visual and physical similarity to previously-sampled materials or based on date of application. Sample collection procedures are outlined in a later section.

Task 4–Quantity Takeoff Upon analysis of the sampled materials by the independent laboratory, ESI prepared a list of hazardous materials (in this report), and measured approximate quantities of material to be abated.

In situations where accurate quantities could not be measured or in case of inaccessible areas (i.e., such as pipe insulation under the pier), ESI performed a best guess estimate and recorded the results in the summary tables listed in the Appendices of this report.

Listed quantities are for budgetary estimates only, and shall be field-verified by all abatement or general contractors prior to bid submission.

Report for PCB, Mercury Vapor, Asbestos & Lead Paint Inspection & Sampling at Page 6 MOTCO — Pier 2, Building A21 & Building 100 — Concord, California EnviroScience, Inc.

C. EQUIPMENT, TOOLS, AND INSTRUMENTS

Asbestos-Containing Materials Sample Collection Procedures Bulk samples of suspect ACMs were collected using a core sampler or by carefully scraping a small portion of a suspect material or surface. The sampled material was immediately contained in a plastic ziplock bag, and the surface area was reconditioned with encapsulant or tape (where applicable) to prevent fiber release. In areas where the sampled material posed a high risk of fiber release, a half-face type H respirator equipped with dual HEPA cartridges was worn by the inspector for respiratory protection. Samples were then properly labeled with a unique sample identification number, sample locations were marked on building floor plans, and the sampling information was recorded in ESI’s bound field notebook. Properly-labeled and packaged bulk samples were then delivered in person or via overnight mail to a NVLAP-certified independent laboratory, for analysis along with a signed copy of chain-of-custody documentation.

Sample Analysis Procedures All ACM samples were analyzed at a State certified independent laboratory (EMSL Analytical, Inc., of San Leandro, CA), by the EPA-recommended method of polarized light microscopy (PLM). Samples were examined for homogeneity and percent composition of fibrous versus nonfibrous components using a 20x stereoscopic microscope. A small portion of the material was placed in refractive index liquid on a microscope slide and examined for the presence of asbestos species utilizing a polarized light microscope at a magnification of 100x to 200x. Crystallographic and dispersion-staining techniques were employed for positive characterization. If the presence of asbestos was confirmed, the percentage of asbestos versus non-asbestos material was visually estimated & recorded.

Lead-Containing Paints Sample Collection Procedures Samples of paint were collected by carefully scraping approximately 1 gram or about 1 teaspoon of the paint surface. The paint was either peeled from the substrate or scraped to the substrate, avoiding dust. ESI's on-site inspector tried to minimize the amount of substrate submitted with the paint, as this would affect the true concentration of lead in the paint. The sampled material was immediately contained in plastic ziplock bags and the surface area was reconditioned with encapsulant or spray paint (where applicable) to prevent exposure. In areas where sampled material posed a high risk of dust release, a half-face type H respirator equipped with dual HEPA cartridges was worn by the inspector for respiratory protection. All sampling information was recorded in bound field notebooks.

Properly-labeled and packaged paint chip samples were then delivered in person or via overnight mail to a NVLAP-certified independent laboratory, for analysis along with a signed copy of chain-of-custody documentation Sample Analysis Procedures Samples of suspect paint were analyzed in accordance with EPA Method 7420, analysis by Atomic Absorption (AA) direct aspiration and results were reported in percent by weight.

AA spectroscopy is a laboratory analytical technique that provides precise determination of specific inorganic elements. These elements are more commonly referred to as "metals."

There are approximately 65 metallic elements including lead, aluminum, tin, silver and copper. AA refers specifically to the reaction of metal atoms to heat. When these atoms are exposed to very high heat or are atomized in other ways, they absorb light. Each element absorbs light of a specific wave length & the absorption of light is directly proportional to the concentration of atoms in solution. The sample results were reported in percent of lead by weight.

Report for PCB, Mercury Vapor, Asbestos & Lead Paint Inspection & Sampling at Page 7 MOTCO — Pier 2, Building A21 & Building 100 — Concord, California EnviroScience, Inc.

D. INSPECTION SUMMARY

Based on ESI’s visual inspection and the analytical findings of the samples collected on Site, it is confirmed that the following hazardous construction materials are present on Site.

Asbestos-Containing Materials (ACMs) Pier 2 & Building A21

1. Wall & ceiling wallboard surfaces throughout, contain <1-2% Chrysotile-type asbestos in the joint compound and textured skim coat;

2. All thermal system insulation (TSI) in the form of pipe straight runs, elbows, tees, and valve covers under the pier, and throughout the balance of the main Building (if any) contains 10% Amosite, and 3% Chrysotile-type asbestos;

and

3. The 2 pipes under the length of the Pier are Transite. By definition Transite contains asbestos fibers, and ESI thus assumes that these 2 pipes or any other similar pipe on Site are asbestos containing.

Portable Building 100

1. No asbestos detected in this portable structure.

Lead-Based Paints Pier 2 & Building A21

1. The red-colored peeling paint on the exterior of all sprinkler pipes contains

560,000 parts per million (ppm) or 56% lead (this concentration is extremely high);

2. The grey-colored paint on the wood walls of the room next to the bathrooms contains 3,900 ppm or 0.39% lead;

3. The beige on green-colored peeling paint on the walls and ceiling of the center office (similar throughout) contains 320 ppm or 0.032% lead;

4. The brown-colored peeling paint on bathroom door louvers does not contain any lead (i.e., less than limit of detection);

5. The white-colored peeling paint on the overhead pipes in the last open section does not contain any lead (i.e., less than limit of detection);

6. The white-colored peeling paint on the ceiling rafters of the last open section contains 4,800 ppm or 0.48% lead;

7. The red on yellow-colored peeling paint on sprinkler pipes under the pier contains 70,000 ppm or 7% lead;

8 . The beige-colored peeling paint on exterior wood sidings of Building A21 contains 120,000 ppm or 12% lead; and

9. The beige-colored peeling paint on exterior doors of Building A21 does not contain any lead (i.e., less than limit of detection).

Portable Building 100

1. The beige-colored peeling paint on the exterior door of the Portable contains 760 ppm or 0.076% lead.

Report for PCB, Mercury Vapor, Asbestos & Lead Paint Inspection & Sampling at Page 8 MOTCO — Pier 2, Building A21 & Building 100 — Concord, California EnviroScience, Inc.

Polychlorinated Biphenyls (PCBs) Ballasts (transformers) inside all fluorescent light fixtures and the cooling liquid inside the three (3) electrical transformers in Building A21 are assumed to contain polychlorinated biphenyls (PCBs). These regulated liquids shall be properly disposed of or incinerated.

Ballasts inside Fluorescent Fixtures Electrical Transformers (Assumed to contain PCB) (Assumed to contain PCB)

Mercury Vapor Tubes & Bulbs Fluorescent light tubes in all light fixtures, and the Metal Halide bulbs in all flood lights on the Pier and on or around Buildings A21 and 100 are assumed to contain mercury vapor and/or other hazardous gases, which must be recycled at an approved recycling facility.

Metal Halide Light Bulbs Fluorescent Light Tubes (Assumed to contain Mercury & other gases) (Assumed to contain Mercury vapor)

Report for PCB, Mercury Vapor, Asbestos & Lead Paint Inspection & Sampling at Page 9 MOTCO — Pier 2, Building A21 & Building 100 — Concord, California EnviroScience, Inc.

E. REGULATIONS

The National Emission Standard for Hazardous Air Pollutants (NESHAP) regulations is part of the Clean Air Act and is found in 40 CFR 61 part M. NESHAP requires that building owners inspect a building (regardless of age) for asbestos prior to renovation or demolition. The EPA must be notified in advance of all demolitions and when more than a listed amount of Regulated Asbestos-Containing Material (RACM) are going to be disturbed during a renovation or demolition. Furthermore, construction work disturbing RACMs by unlicensed and non-registered asbestos abatement contractors are prohibited by California and Federal laws.

The United States Environmental Protection Agency (US EPA) considers a material to be asbestos-containing if at least one homogeneous sampling material confirms presence of asbestos fibers greater than one percent (>1%). Asbestos-containing materials (ACM) are regulated by federal, state, and local agencies.

EPA classifies ACMs into the following three (3) categories:

• Friable ACM — Asbestos-containing materials which can be pulverized into dust by hand pressure (definition of friability);

• Category I non friable ACM — Asbestos-containing asphalt roofing products, vinyl floor tiles, gaskets, sealants, and other packing material;

• Category II non friable ACM — All asbestos-containing materials other than

Category I non-friable, that when dry, cannot be pulverized or reduced to powder by hand pressure.

The above-referenced ACM categories can become Regulated-Asbestos Containing Materials (RACM) under certain conditions (i.e., demolition or renovation). These conditions are:

• Friable ACM;

• Category I non friable ACM which has become friable;

• Category I non friable ACM which has been, or will be subjected to cutting, grinding, sanding, or other abrasive contact;

• Category II non friable ACM which has, or will be, pulverized, crumbled, or reduced to powder under mechanical forces exerted during demolition or renovation operations.

Report for PCB, Mercury Vapor, Asbestos & Lead Paint Inspection & Sampling at Page 10 MOTCO — Pier 2, Building A21 & Building 100 — Concord, California EnviroScience, Inc.

F. RECOMMENDATIONS FOR ABATEMENT

Asbestos-Containing Materials This survey was conducted in anticipation for demolition of Pier 2, Building A21, and the relocation of Portable Building 100. As stated previously, under EPA's NESHAP regulation 11 Rule 2, all confirmed and assumed ACMs shall be properly abated from a facility prior to demolition or other disturbance.

ACM abatement shall be conducted by workers with proper personal protective equipment (PPE), under full or partial containment (depending on the friability of the ACM), and using wet removal procedures. According to OSHA Construction Industry Standard for asbestos (29CFR 1926.58), and the general industry asbestos standard (29CFR 1019.1001) workers performing asbestos abatement must be trained, equipped with respirators with full body protection, and must be medically fit to wear respirators, as certified by an independent physician.

Certain ACMs such as Transite pipes are considered non-friable in their current undisturbed state. The Bay Area Air Quality Management District (BAAQMD), the regulating agency of EPA in the Bay Area, states however, that non-friable material may and will become friable under the forces of demolition. It is thus recommended that all identified ACMs, friable and non-friable, to be abated under regulated or contained conditions by a State-licensed and DOSH-registered asbestos abatement contractor. All abatement shall be conducted using wet procedures and asbestos waste shall be packaged in accordance with EPA's NESHAP regulation (40CFR Parts 61 and 763) and according to California Department of Health Services, California Code of Regulations, Title 22, Division 4, Chapter 30, Section 66699 and Health and Safety Code 25179.3 et. seq.

Lead-Based Paints NOTE: Not all lead-based paint needs to be abated. Paint, which is flaking from the substrate (as on fire sprinkler lines), or paint that may be subject to cutting or grinding (as in pipe cutting) and may pose a respiratory health hazard during demolition or under forces of demolition, shall be dealt with in accordance with regulations.

Construction work where employees may be exposed to lead shall be performed in compliance with California Code of Regulations, Title 8, Section 1532.1 "Lead in Construction."

Occupational exposure to lead is regulated by the Federal Occupational Safety and Health Administration (OSHA) section 29 CFR 1926.62. This standard requires that the employer shall assure that no employee is exposed to lead dusts or fumes at concentrations greater than fifty micrograms per cubic meter (50 µg/m3) of air, averaged over an eight-hour period. This is known as the Permissible Exposure Level (PEL). Since the lead content of the painted surfaces at the above-referenced locations range from 8,820-283,000 ppm, the chance of employee exposure to lead dusts above PEL exists. In accordance with the above-referenced OSHA regulations, the employer shall limit employee exposure to lead by using appropriate respiratory protection.

If the potential for exposure to lead dusts or fumes exists (both indoor & outdoor), the contractor should perform personal air monitoring in accordance with OSHA Regulation 29 CFR Part 1926.62 and DOSH Title 8 CCR Sections 1532.1 and 5216. Work practices must be such that the 8-hour time weighted average (TWA) permissible exposure limit shall

Report for PCB, Mercury Vapor, Asbestos & Lead Paint Inspection & Sampling at Page 11 MOTCO — Pier 2, Building A21 & Building 100 — Concord, California EnviroScience, Inc.

not exceed 50µg/m3. If any worker exposure exceeds the action level of 30 µg/m3, work practices causing the elevated lead levels shall cease or be modified. Rags and paint debris shall be treated as hazardous waste if laboratory results indicate a lead (Pb) concentration of 5 milligrams per liter or greater using the EPA-approved Toxicity Characteristic Leaching Procedure (TCLP) test or equivalent, or greater than 1,000 mg/Kg using the total lead assay.

The selected contractor shall be fully responsible for compliance with the Cal-OSHA lead standard as contained on Title 8 CCR Section 1532.1. If 8-hour time weighted average (TWA) exposures exceed the action level of 30 micrograms of lead per cubic centimeter of air µg/m3), the Contractor must continue to conduct periodic air monitoring at specified intervals, and institute medical surveillance and training programs. If the Cal-OSHA permissible action level (PEL) of 50 µg/m3 for lead is exceeded, more stringent and additional requirements become effective, such as engineering controls, respiratory protection, regulated work areas, and warning signs in lead work areas.

The contractor and its sub-contractors, as applicable shall take necessary precautions to prevent the release of lead in the form of dust, fumes, or mists from the identified lead-containing building materials into the air or onto surrounding environments (both indoor & outdoor). The Contractor shall inform all workers, supervisory personnel and authorized visitors on the job site of the potential hazards of lead and of necessary precautions and housekeeping procedures to reduce the potential for exposure in areas where lead is known to be present, even at levels well below 5,000 ppm.

Polychlorinated Biphenyls (PCBs) Ballasts (transformers) inside all fluorescent light fixtures and the cooling liquid inside the electrical transformers in Building A21 are assumed to contain polychlorinated biphenyls (PCBs). PCB is RCRA-regulated waste and must be disposed of at a Class I hazardous waste landfill, after proper manifesting. PCB-containing light ballasts, and the transformers may also be disposed of by incineration at an approved facility. The selected abatement contractor is responsible for the removal and packaging of all encountered PCB-containing ballasts and transformers on Site, for proper disposal. Ballasts are recommended to be packaged inside DOT-approved steel drums in between layers or sawdust or other absorbent material prior to transport to the landfill or incineration facility. Personnel removing ballasts shall wear personal protective equipment in the form of respiratory, body, hand, and eye protection. Personnel must exercise extreme care in not breaking transformers open.

Mercury Vapor Tubes & Bulbs Fluorescent light tubes in all light fixtures, and the Metal Halide bulbs in all flood lights on the pier and the building are assumed to contain mercury vapor and/or other hazardous gases. Release of such vapors into the atmosphere by breaking the tubes or bulbs is harmful to human health and the environment. The selected abatement contractor shall carefully remove all fluorescent light tubes & metal halide bulbs from the light fixtures and package them inside cardboard or other similarly protective boxes to eliminate breakage during transport. All such packaged tubes & bulbs shall then be transferred to a recycling facility for proper disposal.

Report for PCB, Mercury Vapor, Asbestos & Lead Paint Inspection & Sampling at Page 12 MOTCO — Pier 2, Building A21 & Building 100 — Concord, California EnviroScience, Inc.

G. REQUIREMENTS FOR AIR MONITORING DURING

FRIABLE ASBESTOS ABATEMENT

Asbestos-containing thermal system insulation (TSI), and skim coat on wallboard surfaces are both considered to be friable (i.e., they can be pulverized to dust by hand pressure).

Subsequently, these materials are identified as “Regulated Asbestos-Containing Materials (RACM)” in accordance with Code of Federal Regulations (CFR) 40 CFR Part 61.141.

Removal of RACM is defined by 29 CFR 1926.1101 “Occupational Exposure to Asbestos

– Construction Industry Standard” as Class I asbestos work.

29 CFR 1926.1101 (e) (1) sates that all Class I asbestos work “shall be conducted within regulated areas.” Section (g) (4) titled Class I Requirements, further require the employer to use one of the following methods to ensure that airborne asbestos does not migrate from the regulated area:

(A) Critical barriers shall be placed over all openings to the regulated area, except where activities are performed outdoors; or

(B) The employer shall use another barrier or isolation method which prevents the migration of airborne asbestos fibers from the regulated area, as verified by perimeter area surveillance during each work shift at each boundary of the regulated area, showing no visible asbestos dust; and perimeter area monitoring showing that clearance levels contained in 40 CFR Part 763, Subpart E, of the EPA Asbestos in Schools Rule are met, or that perimeter area levels, measured by Phase Contrast Microscopy (PCM) are no more than background levels representing the same area before the asbestos work began. The results of such monitoring shall be made known to the employer no later than 24 hours from the end of the work shift represented by such monitoring.

To comply with the requirements of 29 CFR 1926.1101 (g) (4) (A) and (B), cited above, the abatement contractor needs to construct an enclosure system (even around outdoor pipes) to prevent migration of asbestos fibers outside the regulated area.

Furthermore, 29 CFR 1926.1101 (g) (4) (B), states that migration of fibers outside the regulated area (both indoor & outdoor) are to be measured by daily perimeter air monitoring and analysis by PCM. The perimeter monitoring will also assure than non-employees (i.e., adjoining tenants, visitors, and other workers) in the close vicinity of the Class I asbestos-related work, are not being exposed to airborne asbestos particles.

To ensure adequacy and integrity of the containment during friable asbestos removal, the owner shall engage the services of an independent industrial hygiene (IH) consultant, to perform independent air quality monitoring at the perimeter of the containment(s) as required by 29 CFR 1926.1101 (g) (4) (B).

Upon proper completion of all abatement, the independent IH consultant shall also perform a detailed visual inspection of all abated surfaces, to certify that all ACM has been properly abated, packaged, and removed from the facility. Following the successful visual inspection, all abated surfaces shall be locked down using an approved bridging type encapsulating agent, following which, the IH consultant shall perform final clearance air quality monitoring. Only after confirmation of the final clearance air samples below the EPA-recommended level of 0.010 fibers/cc (by PCM), may non-protected workers or other personnel be allowed to enter the area to perform demolition or other construction tasks.

Report for PCB, Mercury Vapor, Asbestos & Lead Paint Inspection & Sampling at Page 13 MOTCO — Pier 2, Building A21 & Building 100 — Concord, California EnviroScience, Inc.

H. LIMITATIONS

This report was prepared solely for the use of our client, GEI Consultants, Inc., and their designated Client(s), only.

No part of this report shall be copied or used for any purpose by anyone other than the client, without written consent from ESI. Any reliance on this report by a third party is at such party's sole risk. The contents and conclusions provided by ESI in this report are based on very limited information collected during its assessment, which include, but are not limited to, visual Site inspection, limited sampling and analysis, and our professional judgment.

Due to safety reasons, ESI did not attempt to perform destructive sample collection under building components, pier surfaces or other inaccessible areas. During demolition activity certain materials may be discovered behind these surfaces, which would have to be dealt with at the time of discovery.

ESI assumes that the samples collected and analytical data presented herein, are reasonably representative of the entire area of the Site inspected, which may not be the case at unsampled areas or materials. The results of the sampling and the recommendations made are applicable to a small window of time on the date, time, and location that sampling was conducted. Any generalization of these recommendations to others dates, times, or locations will not be applicable or accurate.

This report is issued with the understanding that it is the responsibility of the owner, or its representatives, to ensure that the information contained herein is brought to the attention of the appropriate regulatory agencies, where required by law. Additionally, it is the sole responsibility of the owner to properly dispose of any hazardous substances on site, in accordance with existing laws and regulations.

This assessment was performed in accordance with generally accepted principles and practices of environmental engineering and assessment in northern California at the time of the work. This report presents our professional opinion based on our findings, technical knowledge, and experience working on similar projects. No warranty, either expressed or implied, is made. The limited conclusions presented are based on the current regulatory climate. We are not responsible for the impact of any changes in environmental standards or regulations in the future.

To the fullest extent permitted by law, Client agrees to limit the liability of ESI, its officers, shareholders and employees, for any acts, errors or omissions or breaches of contract to the greater of $2,500 or the amount of ESI's fees for services rendered under this Agreement.

Client agrees to defend, indemnify and hold ESI harmless from any loss, cost, damage or expense, including attorney's fees, in excess of the foregoing limits. In no event shall ESI be liable for, and Client shall indemnify and hold ESI harmless against, any indirect, special or consequential loss or damage. Failure of Client to give written notice to ESI of any claim of negligent act, error or omission within one (1) year of performance shall constitute a waiver of such claim by Client.

ESI will retain the records related to this project including lab data for a period of six (6) months from the date of this investigation, only. Thereafter all paper and electronic records will be discarded safely. It will be the responsibility of the client to retain all records related to this project after the 6-month period. ESI assumes no responsibility for document reproduction in legal dispute matters after the 6-month expiration period.

Report for PCB, Mercury Vapor, Asbestos & Lead Paint Inspection & Sampling at Page 14 MOTCO — Pier 2, Building A21 & Building 100 — Concord, California EnviroScience, Inc.

There are no third party beneficiaries of this agreement between Client and ESI and no third party shall be entitled to rely upon any work performed or reports prepared by ESI hereunder for any purpose. Client shall indemnify and hold ESI harmless against any liability to any third party for any loss, expense, or damages arising out of or in connection with reliance by any such third party on any work performed or reports issued by ESI hereunder.

Report for PCB, Mercury Vapor, Asbestos & Lead Paint Inspection & Sampling at Page 15 MOTCO — Pier 2, Building A21 & Building 100 — Concord, California EnviroScience, Inc.

I. Summary Tables (For Asbestos, Lead & Universal Waste)

Report for PCB, Mercury Vapor, Asbestos & Lead Paint Inspection & Sampling at Page 16 MOTCO — Pier 2, Building A21 & Building 100 — Concord, California EnviroScience, Inc.

TABLE 1

SUMMARY OF ASBESTOS SAMPLING AT

MOTCO — Pier 2 — Building A21 Concord California

I ESTIMATED

T MATERIAL ASBESTOS SAMPLE ABATEMENT

E SAMPLED CONTENT LOCATION QUANTITY

M ( R e m e d i a t i o n Budget)

MOT- Wallboard Skim 2% C* Walls of the water heater All wallboards in A21 L1 Joint Compound Joint 2% C room behind the bathrooms ≈ 10,000 sq. ft.

Wallb’d ND** (≈ $30,000)

MOT- 12”x12” Vinyl Floor ND Inside room next to N/A L2 Tiles (Grey) bathrooms

MOT- Wallboard Skim <1% C Walls of the Included in item L1 L3 Joint Compound Joint 2% C Center Office

Wallb’d ND

MOT- 12”x12” Vinyl Floor ND Under carpets of the N/A L4 Tiles (White) center office

MOT- Wallboard Texture 2% C Walls of the N/A L5 Texture Wallb’d ND center office

MOT- 12”x12” Vinyl Floor ND Floor of the N/A L6 Tiles (Grey) Bathroom

MOT- Wallboard ND Wall of the N/A L7 Joint Compound Bathrooms

MOT- Baseboard ND Behind vinyl baseboards N/A L8 Mastic (Brown) in the bathrooms

MOT- Wall ND Wall of the N/A L9 Plaster bathrooms

MOT- Thermal System 10% A*** Pipes under the pier 1,200 lin. ft.

L10 Insulation (TSI) 3% C (12” OD) — Covered in metal (≈ $9,000)

MOT- Insulation Tape ND Around fire sprinkler N/A L11 (Black) pipes

MOT- Asphalt ND Entire roof of N/A L12 Roof Shingles building A21 c

— Transite pipes ASSUMED 2 pipes under the length ≈ 2,400 lin. ft.

of the pier (≈ $9,000)

* Chrysotile-type asbestos ** None Detected *** Not Applicable (no abatement needed)

Report for PCB, Mercury Vapor, Asbestos & Lead Paint Inspection & Sampling at Page 17 MOTCO — Pier 2, Building A21 & Building 100 — Concord, California EnviroScience, Inc.

TABLE 2

SUMMARY OF ASBESTOS SAMPLING AT

MOTCO — Pier 2 — Building 100 Concord California

I ESTIMATED

T MATERIAL ASBESTOS SAMPLE ABATEMENT

E SAMPLED CONTENT LOCATION QUANTITY

M ( R e m e d i a t i o n Budget)

L1 12” x 12” vinyl floor tiles Tile — ND* Potable 100 – N/A (Grey) Mastic — ND Entire Floor

L2 2’x4’ ceiling tiles ND Potable 100 – N/A (White) Entire Ceiling

L3 Caulking Material ND Potable 100 – N/A (Beige) Along edges of exterior wood siding

L4 Adhesive mastic ND Potable 100 – N/A (Grey) Peeling mastic along roof edges

Report for PCB, Mercury Vapor, Asbestos & Lead Paint Inspection & Sampling at Page 18 MOTCO — Pier 2, Building A21 & Building 100 — Concord, California EnviroScience, Inc.

TABLE 3

SUMMARY OF LEAD PAINT SAMPLING AT

MOTCO — Pier 2 — Building A21 Concord California

I ESTIMATED

T PAINT LEAD PAINT PEELING

E SAMPLED CONCENTRATION LOCATION QUANTITY

M ( R e m e d i a t i o n Budget)

MOT- fire sprinkler pipes 56% All fire sprinkler lines ≈ 500 lin. ft.

P1 (Red - Peeling) (560,000 ppm)* (1” – 12” OD) (≈ $10,000)

MOT- Wood siding paint 0.39% Walls of the room None Peeling P2 (Grey) (3,900 ppm) next to the bathroom

MOT- Interior wall paint 0.032% Walls of the ≈ 1,000 sq. ft.

P3 (Beige on Green - Peeling) (320 ppm) center office (≈ $5,000)

MOT- Door louver paint <0.039% Bathroom door No lead P4 (Brown - Peeling) (<LOD**) louvers (None)

MOT- Overhead pipe paint <0.010% Overhead pipes No Lead P5 (White - Peeling) (<LOD) in the open section (None)

MOT- Wall & ceiling paints 0.48% Walls & ceiling of the ≈ 5,000 sq. ft.

P6 (White - Peeling) (4,800 ppm) open section (≈ $25,000)

TABLE 3 (Cont’d)

Report for PCB, Mercury Vapor, Asbestos & Lead Paint Inspection & Sampling at Page 19 MOTCO — Pier 2, Building A21 & Building 100 — Concord, California EnviroScience, Inc.

SUMMARY OF LEAD PAINT SAMPLING AT

MOTCO — Pier 2 — Building A21

Concord California

I ESTIMATED

T PAINT LEAD PAINT PEELING

E SAMPLED CONCENTRATION LOCATION QUANTITY

M ( R e m e d i a t i o n Budget)

MOT- Fire sprinkler paint 7% Large fire sprinkler ≈ 500 lin. ft.

P7 (Red on Yellow - Peeling) (70,000 ppm) lines under the pier (≈ $10,000)

MOT- Exterior siding paint 12% All exterior surfaces ≈ 3,000 sq. ft.

P8 (Beige - Peeling) (120,000 ppm) of Building A21 (≈ $15,000)

MOT- Exterior door & <0.033% All exterior doors ≈ 500 sq. ft.

P9 frame paint (<LOD) of Building A21 (≈ $2,500)

(Beige - Peeling)

* Part per Million ** Limit of Detection *** Not Applicable (No Lead)

Report for PCB, Mercury Vapor, Asbestos & Lead Paint Inspection & Sampling at Page 20 MOTCO — Pier 2, Building A21 & Building 100 — Concord, California EnviroScience, Inc.

TABLE 4

SUMMARY OF LEAD PAINT SAMPLING AT

MOTCO — Pier 2 — Building 100 Concord California

I ESTIMATED

T PAINT LEAD PAINT LOOSE & PEELING

E SAMPLED CONCENTRATION LOCATION QUANTITY

M ( R e m e d i a t i o n Budget)

P1 Exterior door paint 0.076% Peeling paint on ≈ 25 sq. ft.

(Beige) (760 ppm*) the exterior door ( ≈ $250)

* Parts Per Million

Report for PCB, Mercury Vapor, Asbestos & Lead Paint Inspection & Sampling at Page 21 MOTCO — Pier 2, Building A21 & Building 100 — Concord, California EnviroScience, Inc.

TABLE 5

SUMMARY OF UNIVERSAL WASTE AT

MOTCO — Pier 2 — Building A21 Concord California

I ESTIMATED

T UNIVERSAL HAZARDOUS LOCATION REMEDIATION

E WASTE CONTENT QUANTITY

M CATEGORY (Remediation Budget)

1 Fluorescent light Assumed Inside all fluorescent ≈ 120 tubes tubes to contain Light tubes ($1,200)

Mercury & other Vapors

2 Metal Halide Assumed Inside all flood ≈ 40 bulbs bulbs to contain Lights ($1,000)

Mercury Vapor

3 Fluorescent light Assumed Inside all fluorescent ≈ 60 ballasts ballasts to contain Light fixtures ($1,800)

PCBs

4 Electrical Assumed Inside Building A21 ≈ 3 Transformers transformers to contain Electrical Room ($5,000)

PCBs

Report for PCB, Mercury Vapor, Asbestos & Lead Paint Inspection & Sampling at Page 22 MOTCO — Pier 2, Building A21 & Building 100 — Concord, California EnviroScience, Inc.

J. Site Plan of MOTCO — Pier 2 (Pier 2, Building A21 & Building 100 Sampled) — Building 160 already demolished by others

BUILDING A21

(TO BE DEMOLISHED)

BUILDING 160

(ALREADY DEMOLISHED)

PIER 2

(TO BE DEMOLISHED)

Report for PCB, Mercury Vapor, Asbestos & Lead Paint Inspection & Sampling at Page 23 MOTCO — Pier 2, Building A21 & Building 100 — Concord, California EnviroScience, Inc.

K. Asbestos & Lead Sample locations — Building A21

Report for PCB, Mercury Vapor, Asbestos & Lead Paint Inspection & Sampling at Page 24 MOTCO — Pier 2, Building A21 & Building 100 — Concord, California EnviroScience, Inc.

L. Analysis and Test Results for Asbestos Samples (By an Independent Laboratory)

Report for PCB, Mercury Vapor, Asbestos & Lead Paint Inspection & Sampling at Page 25

Report for PCB, Mercury Vapor, Asbestos & Lead Paint Inspection & Sampling at Page 26

Report for PCB, Mercury Vapor, Asbestos & Lead Paint Inspection & Sampling at Page 27

Report for PCB, Mercury Vapor, Asbestos & Lead Paint Inspection & Sampling at Page 28

Report for PCB, Mercury Vapor, Asbestos & Lead Paint Inspection & Sampling at Page 29 MOTCO — Pier 2, Building A21 & Building 100 — Concord, California EnviroScience, Inc.

M. Analysis and Test Results for Lead Paint Samples (By an Independent Laboratory)

Report for PCB, Mercury Vapor, Asbestos & Lead Paint Inspection & Sampling at Page 30

Report for PCB, Mercury Vapor, Asbestos & Lead Paint Inspection & Sampling at Page 31

A4.2_West Trestle and Personnel Trestle Seismic Analysis_rev2 (2014-12-31)

A12.3_MOTCO VE Imp Charrette Mtg Minutes (2015-07-30) FINAL