A01.10_Attachment_10-App_9_Pine_Flat_Dam_LBP_Report.pdf

Leon Environmental Services

Richard “Danny” Leon CAC # 04-3708 Tommy Leon CAC # 05-3882

5637 N. Figarden Drive, Suite 104, Fresno, CA 93722 Phone: 559.274.9200 Fax: 559.274.9240 Email: leonenviro@comcast.net

April 24, 2012

Mr. Sheldon Pittman US Army Corps of Engineers P.O.Box 117 27295 Pine Flat Road Piedra, CA 93649

Re: Lead Based Paint Report Pine Flat Dam Our Job No. L02-12

Dear Sheldon

Attached is the Lead Based Paint Report for the above-referenced site. The report includes XRF analysis results and recommendations concerning lead containing paint at this site.

If you have any questions or need additional information, please do not hesitate to call. Thank you for using Leon Environmental Services. We look forward to working with you in the future.

Respectfully yours, Richard “Danny” Leon

California Dept. of Public Health Lead-Related Construction Inspector/Assessor ID# 5156

5637 N. Figarden Dr., Suite 104, Fresno, CA 93722 Phone: 559.274.9200 Fax: 559.274.9240 Email: leonenviro@comcast.net

Leon Environmental Services

LEAD BASED PAINT ANALYSIS RESULTS

Twenty-one samples of suspect lead based paint were analyzed on the Dam gates, catwalk and gate motor support structural steel by Leon Environmental Services using a Niton XLp X-Ray Fluorescence (XRF) Elemental Analyzer, Model 300A, Serial Number 26902. The attached Table 1 contains the list of all samples taken.

LBP COMMENTS AND RECOMMENDATIONS

The 2 samples from the structural steel supporting the gate motors contain more than 1.0 mg/cm2 and are therefore considered lead based paint. All other readings were well below the level of 1.0 mg/cm2 and are therefore NOT LBP.

Leon Environmental Services recommends that only a qualified Contractor with properly LBP trained and equipped personnel be used to work on or near these LBP painted surfaces. All loose and flaky LBP should be removed prior to demolition or renovation, collected and handled as one waste stream.

Procedures and engineering controls must be designed to follow CAL-OSHA (CFR 1926.62) and Department of Health Services (Title 17 April 2008) requirements.

LBP CONCLUSIONS AND REGULATIONS

The federal and CAL OSHA regulations for lead in construction do not specify a level of lead in paint that classifies it as LBP, although the Department of Housing and Urban Development (HUD) considers a paint to be a lead-based paint when the content of the paint exceeds 1.0 mg/cm2 or 0.5 percent lead by weight and the Consumer Product Safety Commission (CPSC) has determined that for a paint to be considered as “lead free”, it must contain less than 0.06% or 600 parts per million (PPM). However, federal and state OSHA regulations specify airborne lead levels that should not be exceeded during construction without appropriate protection and training.

In California, the Department of Occupational Safety and Health is charged with implementing and enforcing Lead in Construction rules. Title 8 of the California Code of Regulations (CCR) section 1532.1 requires employers to provide sufficient worker protection when any detectable concentration of lead is present.

This standard applies to all sources of lead, including lead in painted surfaces.

Lead-Containing paint, defined as any detectable concentration of lead, does not necessarily require special handling, mitigation or disposal. Factors that determine the appropriate mitigation strategy include the concentration of lead, the condition of the lead-containing material, and the proposed contractor work methods. Employers are required to provide sufficient worker protection when any detectable concentration of lead is present.

LEAD BASED PAINT INSPECTION REPORT

Pine Flat Dam, Piedra, CA

Phone: 559.274.9200 Fax: 559.274.9240 Email: leonenviro@comcast.net

California Occupational Safety and Health (OSHA 29 CFR 1926.62) regulations require employee personnel monitoring at any detectable levels until statistically reliable results indicate that exposure will remain consistently below the OSHA Action Level of 30 micrograms/m2 and the Permissible Exposure Level of 50 micrograms/m3 for an 8 hour day. The employer must then produce a “Negative Exposure Assessment” to indicate that it is not possible with the specific lead-based paint product to create excessive lead exposure levels. Cal-OSHA Title 8, CCR Section 1532.1 requires a wide variety of responses including, personal protective equipment (PPE), respiratory protection, blood testing for lead and hand washing facilities if the action level of 30 ug/m3 or the permissible exposure level of 50 ug/m3 are exceeded

California Environmental Protection Agency, Department of Toxic Substances Control, California Heath and Safety Code 25157.8 states waste that contains total lead (TTLC) in excess of 350 to 1000 parts per million (ppm) will be disposed of as a non-hazardous waste at a Class I hazardous waste disposal facility, or a designated facility with appropriate permit modifications. Wastes with total lead less than 350 ppm will not need a hazardous waste manifest or registered hazardous waste transporter when transporting the waste. Further, lead waste streams exceeding 1,000 ppm of Total Lead (TTLC) and/or waste streams with soluble lead exceeding 5.0 mg/l (via soluble threshold limit concentration [STLC] and/or total characteristic leachate concentration [TCLP]) are considered a hazardous waste under federal and/or state regulations.

LIMITATIONS OF LIABILITY

Conclusions and recommendations presented in this report are qualitative judgments based on the prevailing regulations and accepted industry standards at the time of the report issuance. Leon Environmental Services provides no other guarantees, either expressed or implied. All quantities of materials listed herein are estimates for sampling purposes only, and should be verified by Owner representative or an abatement contractor prior to abatement and or demolition.

The nature of demolition and asbestos abatement is such that materials can be uncovered which previously were unknown to exist. Therefore, Leon Environmental Services cannot be responsible for materials not previously detected due to lack of accessibility or concealment, although every effort was made during the inspection to detect all suspect materials. If suspect asbestos or LBP materials other than those included herein are discovered during renovation or demolition, it must be assumed that the materials are Positive, and should be treated accordingly until further testing and analysis is performed.

The data interpretations and recommendations are based solely on information available to Leon Environmental Services at the time of our inspection. The customer recognizes that site conditions or accessibility may vary, from those

LEAD BASED PAINT INSPECTION REPORT

Pine Flat Dam, Piedra, CA

Phone: 559.274.9200 Fax: 559.274.9240 Email: leonenviro@comcast.net encountered at the time of our inspection and sample collection. Varying conditions or access could result in additional information that would lead us to revise conclusions and recommendations. Leon Environmental Services will not be responsible for the interpretation or use by others of information contained within this report.

Richard “Danny” Leon DATE California Dept. of Public Health Lead-Related Construction Inspector/Assessor ID# 5156

*Abbreviation Key:

Asbestos Containing Material – ACM (Contains greater than 1% asbestos by weight) Asbestos Containing Building Material – ACBM (Contains less than 1% asbestos by weight) Vinyl Asbestos Tile – VAT No Asbestos Detected – N.A.D or N.D.

Homogeneous – H Not Sampled – NS

Client Company

Date: Job No.

Inspection Site :

Analysis: Niton XLp X-Ray Fluorescence (XRF) Elemental Analyzer, Model 300A, Serial Number 26902

Date & Time Reading No Units Type Component Color Substrate Results Reading LBP 4/18/2012 13:11 230 mg / cm ^2 PAINT Structural Steel SILVER METAL Positive 31.8 YES 4/18/2012 13:12 231 mg / cm ^2 PAINT Structural Steel SILVER METAL Positive 29.7 YES 4/18/2012 13:12 232 mg / cm ^2 PAINT Hand Rail SILVER METAL Negative 0.28 NO 4/18/2012 13:13 233 mg / cm ^2 PAINT Hand Rail SILVER METAL Negative 0.19 NO 4/18/2012 13:17 234 mg / cm ^2 PAINT Bearing SILVER METAL Negative 0.03 NO 4/18/2012 13:18 235 mg / cm ^2 PAINT Bearing SILVER METAL Negative 0.07 NO 4/18/2012 13:18 236 mg / cm ^2 PAINT Bearing SILVER METAL Negative 0.18 NO 4/18/2012 13:18 237 mg / cm ^2 PAINT Bearing SILVER METAL Negative 0.03 NO 4/18/2012 13:19 238 mg / cm ^2 PAINT Bearing SILVER METAL Negative 0.39 NO 4/18/2012 13:19 239 mg / cm ^2 PAINT Bearing SILVER METAL Negative 0.03 NO 4/18/2012 13:20 240 mg / cm ^2 PAINT Bearing SILVER METAL Negative 0.03 NO 4/18/2012 13:20 241 mg / cm ^2 PAINT Bearing SILVER METAL Negative 0.05 NO 4/18/2012 13:20 242 mg / cm ^2 PAINT Bearing SILVER METAL Negative 0.06 NO 4/18/2012 13:33 243 mg / cm ^2 PAINT DAM GATE SILVER METAL Negative 0.03 NO 4/18/2012 13:33 244 mg / cm ^2 PAINT DAM GATE SILVER METAL Negative 0.29 NO 4/18/2012 13:41 245 mg / cm ^2 PAINT DAM GATE SILVER METAL Negative 0.04 NO 4/18/2012 13:41 246 mg / cm ^2 PAINT DAM GATE SILVER METAL Negative 0.06 NO 4/18/2012 13:42 247 mg / cm ^2 PAINT DAM GATE SILVER METAL Negative 0.15 NO 4/18/2012 13:52 248 mg / cm ^2 PAINT DAM GATE SILVER METAL Negative 0.03 NO 4/18/2012 14:03 249 mg / cm ^2 PAINT DAM GATE SILVER METAL Negative 0.03 NO 4/18/2012 14:03 250 mg / cm ^2 PAINT DAM GATE SILVER METAL Negative 0.03 NO

Table 1: All Samples Collected From Inspection Site

US Army Corps of Engineers

L02-12

Leon Environmental Services 5637 N. Fig Garden Dr., Suite 104, Fresno, CA 93722 Phone: 559.274.9200 Fax: 559.274.9240 Email: LeonEnviro@comcast.net

Pine Flat Dam, 27295 Pine Flat Road, Piedra, CA 93649

Sheldon Pittman

April 23, 2012

L e a d i n C o n s t r u c t i o n Special Emphasis Program

Cal/OSHA Consultation Service California Department of Industrial Relations P. O. Box 420603 • San Francisco, CA 94142-0603

March 2002

Step 2—On all construction jobs where lead is present the following is required:

•Housekeeping. Lead dust on surfaces, espe-cially in eating areas, must be controlled by HEPA vacuuming, wet clean-up, or other effective methods.

•Hand and face washing. Workers must have washing facilities with soap and clean water.

•Training. Workers must receive training on lead hazards and how to protect themselves.

•A written compliance program to assure control of hazardous lead exposures.

•Exposure determination. Employers must assess the amounts of lead breathed by workers. This is usually done by employee breathing-zone air sampling. Air sampling results are used to determine if the protective measures in Step 4 must be taken, as well as the type of respirator that must be worn for protection.

Step 3—For certain highly hazardous tasks, called trigger tasks, special protective measures must be taken—including specified respirators—until the employer determines that worker airborne exposures to lead are below levels specified in Section 1532.1.

•Level 1 trigger tasks Any of the following with lead-containing coat-ings or materials: spray painting, manual demolition, manual scraping or sanding, use of heat gun, power tool cleaning with dust collection system.

Minimum required respirator: half-mask respirator with N-100, R-100 or P-100 filters.

•Level 2 trigger tasks Any of the following with lead-containing coat-ings or materials: using lead-containing mortar, lead burning, rivet busting, power tool cleaning without dust collection system, clean-up activities using dry expendable abrasives, abrasive blasting enclosure movement or removal.

Safety&Health Fact Sheet

Cal/OSHA is conducting a Special Emphasis Program to reduce the hazard from lead in construction affecting workers, their families and the public.

Why a Special Emphasis Program now?

Cal/OSHA is particularly concerned about lead in construction because of:

•Recognition of significant risk to children from take-home lead, even at very low levels of exposure.

•A boom in housing and public works renovation and rehabilitation projects that disturb lead paint.

•The need for greater protection for workers, their families and the public through a focused inspection and consultation effort.

What are the goals of this program?

Significantly reduce lead exposures for workers, their families and the public by:

•Increased enforcement and consultation to get the word out to contractors, workers, and owners of buildings and other structures that lead is a significant hazard in the construction business.

•Informing employers of regulations they must fol-low when lead may be present on a construction job.

•Informing workers of the hazards of lead on the job, and to their families, especially children, from lead carried into vehicles or homes on their bodies, shoes or clothing.

What steps do I take to comply with the Cal/OSHA regulation for lead in construction?

Section 1532.1 in Title 8 of the California Code of Regulations makes construction employers respon-sible, by law, for basic steps in compliance.

Step 1—Recognize the hazard. Lead can be present in a wide range of materials including paints and other coatings, lead mortars, and base metals to be welded on or treated with abrasive blasting. Look at the age of the building or structure, the presence of coatings and other materials that may contain lead, and information from the property owner.

Send samples of materials to be disturbed to a laboratory for lead analysis. Laboratories accredited by the U.S. Environmental Protection Agency National Lead Laboratory Accreditation Program are listed at www.leadlisting.org. Testing methods for lead must meet requirements of Title 8 Section 1532.1(d)(9).

Cal/OSHA Consultation Service Offices For telephone assistance and to request a no-cost consultation at your workplace:

Or toll-free 1-800-963-9424

San Bernardino 909-383-4567 San Diego 619-767-2060 Santa Fe Springs 562-944-9366 Van Nuys 818-901-5754

Fresno 559-454-1295 Oakland 510-622-2891 Sacramento 916-263-0704

Minimum required respirator: air-supplied hood or helmet, or loose fitting hood or helmet powered air-purifying respirator with N-100, R-100 or P-100 filters.

•Level 3 trigger tasks Abrasive blasting, welding, cutting, or torch burning on structures where lead-containing coatings or materials are present.

Minimum required respirator: half-mask supplied air respirator operated in a positive pressure mode.

Pre-job notification is required for jobs involv-ing all trigger tasks. Written notification must reach the nearest Cal/OSHA district office or be made online at www.dir.ca.gov/dosh/Permits.html at least 24 hours before the job starts. See Section 1532.1(p) for details on required information and types of jobs covered.

Protective measures required for all trigger tasks until worker airborne exposures are shown to be below levels specified in Section 1532.1:

•Respirators, protective equipment and clothing.

•Clothing change areas.

•Initial blood testing for lead and zinc protoporphyrin.

•Basic lead hazard, respirator, and safety training.

Also, Section 1532.1(i)(6) requires regulated areas with warning signs for all trigger tasks.

In addition to the specific trigger tasks, whenever there is reason to believe that any other task may cause a hazardous lead exposure, the above protective mea-sures must be taken until the exposure is shown to be below the airborne Permissible Exposure Limit (PEL).

— More resources —

Step 4—Where air sampling shows employee exposures above the PEL from any operation, the following controls are required in addition to those for trigger tasks: respirators appropriate to the levels of exposure measured, clean areas for eating and clothing change, showers, full worker training, and medical monitoring with routine blood testing for lead and zinc protoporphyrin (ZPP).

Certification. On jobs at residential and public access buildings, workers exposed to lead above the PEL—and their supervisors—must receive state-approved training and be certified by the California Dept. of Health Services. [TIP: Information on lead worker certification—phone 800-597-LEAD—or go to www.childlead.com and click on “Prevention”]

What’s in it for me?

Consider the alternatives to compliance: fines up to $70,000 per violation, medical removal payments to workers with high blood lead levels, and costly job shutdowns.

Some companies find that following the Cal/OSHA regulation increases their business because clients want jobs that are safe for both workers and the environment.

Where can I get help?

The Cal/OSHA Consultation Service helps employ-ers at no cost. Employers can request an industrial hygienist to come to a construction job site, show how air sampling is done and assist in employee training. The Consultation Service is independent of Cal/OSHA’s Enforcement Unit.

•At the Cal/OSHA website you can find all Title 8 •regulations, including Section 1532.1 for lead in •construction: www.dir.ca.gov/dosh

•California Department of Health Services •Occupational Lead Poisoning Prevention Program •website: www.dhs.ca.gov/ohb/olppp •phone: 510-622-4332

Questions frequently asked Q. Before starting work on a job that involves distur-bance of paint or other coatings, am I required to have a sample of the paint analyzed for lead content?

A. This is the best way to begin assessing the lead hazard at the jobsite. While not specifically required by the Cal/OSHA regulation, material sampling—com-bined with knowledge of the tasks being done—is the best indicator of the chance of high airborne lead levels, and can help guide the air sampling and exposure control efforts and the choice of required respirators.

Q. If I’m already doing air monitoring and protecting workers with respirators during tasks with high exposures, why do I also need to do blood lead and ZPP monitoring?

A. Blood lead and ZPP monitoring are tools that help assess workers’ total exposure to lead—including through ingestion, unmonitored operations, and lead contamination in the vehicle and home. It is the most important benchmark for answering the question:

“Am I protecting my workers from the hazards of lead on the job?”

Q. How do I get started with a lead medical monitor-ing program and where do I find a physician to do this?

A. The Department of Health Services Occupational Lead Poisoning Prevention Program listed below can help you get started with this program.

•Painting and Decorating Contractors of America •website: www.pdca.org •phone: 703-383-0800

•SSPC: Society for Protective Coatings •website: www.sspc.org •phone: 412-281-2331

•The National Lead Service Providers’ Listing System •website: www.leadlisting.org