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HomeMy WebLinkAbout3955; Survey Report Pajama Drive Reservior; Survey Report Pajama Drive Reservior; 2007-06-293^155 c/> PRE-DEMOLITION ASBESTOS SURVEY & ^ LEAD TESTING REPORT o Project Site: Pajama Drive Reservoir End of Pajama Drive Oceanside, California 92054 Prepared For: Dale A. Schuck City of Carlsbad, California 405 Oak Avenue Carlsbad, California 92008 RECEIVED JUL09200? ENGINEERING DEPARTMENT Prepared By: WINZLER & KELLY CONSULTING ENGINEERS 4180 Ruffm Road, Suite 115 San Diego, California 92123 (858) 244-0440 & Kelly Project .77010 June 29, 2007 CONSULTING ENGINEERS TABLE OF CONTENTS - PRE-DEMOLITION ASBESTOS SURVEY AND LEAD TESTING REPORT SECTION 1 - EXECUTIVE SUMMARY SECTION 2 - MAIN BODY OF REPORT APPENDIX A - CERTIFICATIONS APPENDIX B - ASBESTOS SAMPLE LOCATION/LEAD TESTING ORIENTATION MAP APPENDIX C - ASBESTOS ANALYTICAL DATA (LABORATORY REPORT) APPENDIX D - XRF LEAD DATA TABLE SECTION 1 EXECUTIVE SUMMARY CONSULTING ENGINEERS CONSULTING ENGINEERS EXECUTIVE SUMMARY At the request of the City of Carlsbad, Winzler & Kelly Consulting Engineers (Winzler & Kelly) performed a Pre-demolition Asbestos Survey and Lead Testing Services of the Pajama Drive Reservoir located at the end of Pajama Drive in the City of Oceanside, County of San Diego, California (site). The survey and testing was conducted at the Control Building and the aboveground storage tank of the Pajama Drive Reservoir for the purposes of demolition. The survey was conducted to identify and sample suspect asbestos-containing materials (ACMs) and asbestos-containing construction materials (ACCMs) and to sample representative building components for the presence of lead-containing surface coatings, lead-based paints, and lead-bearing substances (LCSCs, LBPs, and LBSs). The results of the survey and testing indicate that hazardous building materials are present at the subject site. The following table lists the hazardous materials within the subject site, including the location and the estimated total quantity of the hazardous materials. PAJAMA DRIVE RESERVOIR MATERIAL/COMPONENT DESCRIPTION Asbestos-containing Joint Compound Asbestos-containing Window Putty Asbestos-containing Roof Mastic Asbestos-containing Gasket Asbestos-containing (<1%) Concrete Seal Lead-Based Paints (Color/Substrate): Green/Wood Green/Wood Green/Wood Green/Metal Green/Metal Green/Metal LOCATION Interior Walls, Ceiling and Floor Exterior Windows Roof at Penetrations Piping at Flanges Inlet, Outlet and Overflow Pipe Doors Door Jambs Door Frames Tank Exterior Doors of Chlorine Meter Overflow Pipe CONDITION Damaged Damaged Good Good Good Intact Intact Intact Intact Intact Intact ESTIMATED TOTAL QUANTITY (SF/LF/EA) 500 SF 100SF 4SF 15 EA 15 SF SEA 3EA SEA 1,600SF 6SF 25 LF Notes: SF = square feet LF = linear feet EA = each NA = not applicable Asbestos -containing = 1% or greater of asbestos by Polarized Light Microscopy (PLM), as defined by USEPA Asbestos-containing (<1%1 = 0.1% or greater but less than 1% of asbestos by Polarized Light Microscopy (PLM), as defined by Cal/OSHA as asbestos-containing construction materials (ACCMs) Lead-Based Paint = 1 .00 milligrams per square centimeter (mg/cm2) of lead or greater is present, as defined by 1 7 California Code of Regulations (CCR) 35001-36100 Lead-Containing Surface Coatings = 0.10 to 0.99 mg/cm2 of lead present (8 California Code of Regulations [CCR] 1532.1). Refer to the XRF Lead Data Table (Appendix D) for building components and surface coatings considered LCSCs at the subject site. Survey Report - Executive Summary Pajama Drive Reservoir June 29, 2007 Page 1 CONSULTING ENGINEERS At no time should the identified ACMs or ACCMs be drilled, cut, sanded, scraped or otherwise disturbed by untrained personnel. These materials should be removed prior to any activities which will impact these materials. Asbestos disturbance and/or removal operations must be conducted by a Cal/OSHA-registered and State licensed asbestos removal contractor. Disturbance and/or abatement operations should be performed under the direct observation of a California Certified Asbestos Consultant or Certified Site Surveillance Technician. Construction activities involving the potential for impacting ACMs should be conducted in accordance with the requirements of Title 8 of the California Code of Regulations, Section 1529 (8 CCR 1529). For abatement activities which will involve the removal of at least 160 square feet, 260 linear feet, or 35 cubic feet of identified friable ACMs and/or regulated ACMs, notification must be made to the San Diego Air Pollution Control District (SDAPCD). Notification to the SDAPCD must be accomplished ten working days prior to the initiation of such activities. For abatement activities which will involve asbestos-related work of at least 100 square or linear feet, written notification must be made to the Cal/OSHA. Notification to the Cal/OSHA must be accomplished 24 hours prior to the initiation of such activities. Notification to employees and contractors working within the building should be made in accordance with the California Health and Safety Code, Section 25915 et.seq. and Proposition 65. At present there is no state or federal regulation requiring mandatory lead removal or abatement prior to disturbance or demolition of structures with identified lead materials. However, there are applicable Cal/OSHA worker protection and training requirements; Cal/EPA waste disposal requirements, Cal/DHS requirements for public and residential buildings, and SB 460 lead hazard regulations that apply to lead- related construction activities, abatement activities and their associated wastes. The following is a brief discussion and summary of applicable regulatory requirements: 4 Cal/OSHA: Title 8, California Code of Regulation (CCR), Section 1532.1 (8 CCR 1532.1) governs occupational exposure to lead. This regulation requires that prior to initiation of certain activities, referred to as "trigger tasks", workers must be trained, medically evaluated, and properly fitted with respiratory protection, and protective clothing until statistically reliable personal eight-hour time weighted average (TWA) results indicate lead exposure levels below the Personal Exposure Limit (PEL) for each unique task which disturbs lead-based and lead- containing coatings. This process is known as a Negative Exposure Assessment or NEA. If the result of the exposure assessment is above the Action Level (AL) additional monitoring is required and if the result is above the PEL additional exposure monitoring, worker protection (including respirator protection and PPE), training and medical requirements apply. However even where the NEA criteria is met, certain hazard communication training and work practice controls still apply where lead is disturbed. "Trigger tasks" are tasks that are assumed to exceed the PEL pending an exposure assessment and they encompass the majority of construction activities that disturb surface coatings. Examples of "trigger" tasks range from manual paint scraping as a lower expected exposure up to hot work and abrasive blasting as the highest expected exposures, and include any non-listed task that the employer determines may potentially expose employees to lead levels above the AL. Survey Report - Executive Summary June 29, 2007 Pajama Drive Reservoir Page 2 CONSULTING ENGINEERS NOTE - "OSHA does not consider any method that relies solely on the analysis of bulk materials or surface content of lead (or other toxic material) to be acceptable for safely predicting employee exposure to airborne contaminates. Without air monitoring results or without the benefit of historical or objective data (including air sampling which clearly demonstrates that the employee can not be exposed above the action level during any process, operation, or activity) the analysis of bulk or surface samples can not be used to determine employee exposure." OSHA Standard Interpretation 5/8/2000. Furthermore, OSHA states that these rules apply to "any detectable concentration of lead" without a specified detection level. Due to the Consumer Product Safety Commission currently allowing paint to contain up to 600 parts per million (ppm) of lead, the variation of lead content due to aging and weathering, and the variation of detection limits associated with both paint chip and XKF analysis, it is recommended that all painted or coated surfaces be treated as potentially containing lead. Clearly, positive analytical results by either method can be used to indicate that detectable lead is present but negative results cannot be interpreted as conclusively demonstrating the absence of lead. Analytical data of bulk paint/coating materials or surface content (by XRF) of lead can be helpful in evaluation of lead-related environmental risks in general but cannot be used to calculate worker exposures and are not a substitute for employee exposure monitoring. As a result of the above, any employee that works around potential lead-based or lead-containing coatings must have HAZCOM training and personal exposure air monitoring is additionally required for employees that disturb such coatings. Significant additional certification, notification, and work practices are required for materials found to be "lead-based". * Any welding, cutting or heating of metal surfaces containing surface coatings should be conducted in accordance with 29 CFR 1926.354 and 8 CCR 1537. These regulations require surfaces covered with toxic preservatives, and in enclosed areas, be stripped of all toxic coatings for a distance of at least 4 inches, in all directions, from the area of heat application prior to the initiation of such heat application. » Cal/EPA through the Division of Toxic Substance Control (DTSC) regulates disposal of lead hazardous waste (22 CCR Division 4, Chapter 30, Minimum Standards for Management of Hazardous and Extremely Hazardous Wastes). DTSC has issued guidance indicating that architectural debris with intact lead paint is normally expected to be handled as general construction waste. However, waste stream segregation and analysis is still required for all paint or coatirig debris regardless of if the paint or coating is intact on a building component or not. The resulting wastes may be hazardous under California and federal RCRA standards for lead and therefore require proper handling, packaging, labeling, and transportation under a proper manifest to a permitted hazardous waste storage, treatment and disposal facility. * Cal DHS: The Department of Health Services (DHS) has specific requirements (Title 17 Sections 35001 thru 36100 et. al.) for hazard assessment and work in public or residential structures. These regulations require special certifications, work practices, and notification for such activities. * Senate Bill 460 (SB 460): An act to amend Section 1941.1 of the Civil Code, and to amend Sections 17961, 17980, and 124130 of, and to add Sections 17920.10, 105251, 105252, 105253, 105254, 105255, 105256, and 105257 to, the Health and Safety Code, relating to lead abatement. This bill allows for fines and criminal penalties to be levied on any person who is found to have Survey Report - Executive Summary June 29,2007 Pajama Drive Reservoir Page 3 CONSULTING ENGINEERS performed lead abatement without containment or created a measurable lead hazard based upon current DHS standards. The testing for this determination can be initiated by any local or state building inspector, health department inspector, or other designated state or local official. A determination of a lead hazard is not solely based upon the lead content of the paint or coating and can be the result of the disturbance of such materials with low concentrations of lead. Written notification to Cal/OSHA must be accomplished should LBP activities involve more than 100 square or 100 linear feet of removal in accordance with the requirements of 8 CCR 1532.1. Proper written notification to Cal/DHS may be required, depending upon the nature of the abatement activity. It is the contractor's responsibly to confirm the hazardous material quantities present prior to initiating renovation or demolition activities at the subject building. Should materials similar to those identified in this report, or other forms of suspect hazardous materials be present or identified, maintenance personnel/contractors should be instructed to immediately cease work activities which may initiate a fiber release episode, and notify the appropriate management personnel. Report prepared for City of Carlsbad by: teve G.Pitts Environmental Field Engineer Certified Asbestos Consultant #05-3852 DHS Lead Inspector/Assessor #15644 Jerry R.gljefman Hazardous Material Division Manager Certified Asbestos Consultant #97-2324 DHS Lead Inspector/Assessor #5809 Survey Report - Executive Summary Pajama Drive Reservoir June 29, 2007 Page 4 SECTION 2 MAIN BODY OF REPORT CONSULTING ENGINEERS CONSULTING ENGINEERS INTRODUCTION At the request of the City of Carlsbad, Winzler & Kelly Consulting Engineers (Winzler & Kelly) performed a Pre-demolition Asbestos Survey and Lead Testing Services of the Pajama Drive Reservoir located at the end of Pajama Drive in the City of Oceanside, County of San Diego, California (site). The survey and testing was conducted at the Control Building and the aboveground storage tank of the Pajama Drive Reservoir for the purposes of demolition. The survey was conducted to identify and sample suspect asbestos-containing materials (ACMs) and asbestos- containing construction materials (ACCMs) and to sample representative building components for the presence of lead-containing surface coatings, lead-based paints, and lead-bearing substances (LCSCs, LBPs, and LBSs). The survey and testing was conducted on June 13,2007, by Mr. Steve Pitts and Mr. Jerry Sherman. Mr. Jerry Sherman performed report preparation and Mr. Steve Reese performed report review. Mr. Sherman, Mr. Reese and Mr. Pitts, are California Occupational Safety and Health Administration (Cal/OSHA)-Certified Asbestos Consultants and California Department of Health Services (Cal/DHS)-Certified Lead-Related Inspector/Assessors. All members of the survey team are employees of Winzler & Kelly, and have received Hazardous Waste Operations and Emergency Response (HAZWOPER) training in accordance with Title 8 California Code of Regulations (CCR) 5194. Copies of certifications can be found in Appendix A of this document. Building Description The survey and testing was conducted at the Pajama Drive Reservoir located at the end of Pajama Drive in the City of Oceanside, California. The Pre-demolition Asbestos Survey and Lead Testing was conducted at the Control Building and the aboveground storage tank of the Pajama Drive Reservoir for purposes of demolition. Samples were collected from suspect materials that may be impacted during the demolition. METHODOLOGY Asbestos - Survey Methodology Suspect ACMs and ACCMs visual identification was performed by entering representative areas and assessing accessible structural, architectural, and mechanical components for the presence of suspect ACMs or ACCMs. Each suspect ACM or ACCM identified was sampled in accordance with sampling guidelines established by the United States Environmental Protection Agency (USEPA) and 8 CCR 1529. The following summarizes the sampling procedures utilized: 1. The location and total quantity of each ACM, ACCM, and presumed ACM (PACM) was tabulated. 2. These materials were then categorized into homogeneous materials. A homogeneous material is defined as being uniform in texture, color, and date of application. 3. A sampling scheme was developed based upon the location and quantity of the various homogeneous materials. Survey Report - Section 2 June 29, 2007 Pajama Drive Reservoir Page 1 CONSULTING ENGINEERS 4. Bulk samples were collected by trained personnel using an appropriate sampling tool and a leak-tight container. 5. Decontamination of bulk sampling tools to prevent the spread of secondary contamination to subsequent bulk samples. 6. Each bulk sample was individually numbered and recorded on a Bulk Sample Log. 7. A Chain-of-Custody Record was maintained and submitted with the samples to the laboratory. A representative drawing showing asbestos sample locations can be found in Appendix B of this document. Asbestos - Analytical Methodology All bulk samples were analyzed by AmeriSci of Los Angeles, California. AmeriSci is accredited by the National Voluntary Laboratory Accreditation Program (NVLAP), the National Institute of Standards and Technology (NIST) and is a successful participant in the Proficiency Analytical Testing (PAT) Program. Polarized Light Microscopy (PLM) All bulk samples were analyzed by Polarized Light Microscopy (PLM) utilizing dispersion staining techniques in accordance with the USEPA Method: "Method for the Determination of Asbestos in Bulk Building Materials U. S. EPA/600/R-93/116" dated July 1993, and adopted by the NVLAP, NVLAP Test Method Code 18/A01, as affiliated with the NIST. Each sample was subjected to two microscopy examinations. The first examination was performed at 20X magnification using a stereo microscope equipped with an external illuminator. Each sample was examined for layering, homogeneity, and the presence of fibrous and non-fibrous materials. An estimate of the percentage for each sample component, relative to the entire sample volume, was made. When discrete strata are identified as a separate material, fibers are first identified and quantified by layer and then the results are combined to yield an estimate of total percent asbestos present. The second examination was performed at a range from of 100X to 400X magnification using a Polarized Light Microscope equipped with two polarizing filters to observe specific optical characteristics. The use of polarized light allows the determination of refractive indices along specific crystallographic axes. Morphology and color were also observed. A retardation plate was placed at a 45 degree angle between the cross polars to determine the sign of elongation using orthoscopic illumination. Orientation of the two filters such that their vibration planes were perpendicular allowed observation of the birefringence and extinction characteristics of anisotropic particles. Lead-Containing Surface Coatings, Lead-Based Paints, and Lead-Bearing Substances (LCSCs, LBPs, and LBSs) - Testing and Analytical Methodology Potential LCSCs, LBPs, and LBSs were identified via visual identification. The representative, suspect surface coatings were then measured on-site through the use of a NITON XL x-ray fluorescence (XRF) spectrum analyzer, in accordance with the requirements of the manufacturer's performance characteristics sheet (PCS) Survey Report - Section 2 June 29, 2007 Pajama Drive Reservoir Page 2 CONSULTING ENGINEERS for this instrument. For purposes of this survey, and in accordance with Title 8 of the California Code of Regulations, Section 1532.1 (8 CCR 1532.1) and Title 17 of the California Code of Regulations, Section 35001 et. seq., the XRF measurement data results were interpreted as follows: 1. Positive results (LBPs/LBSs present) were determined when analytical results revealed a lead concentration of 1.00 milligrams per square centimeter (mg/cm2) or greater, equivalent to 5,000 parts per million (ppm) or greater. 2. Positive results (LCSCs present) were determined when analytical results revealed a lead concentration of 0.10 mg/cm2 or greater, up to 1.00 mg/cm2. 3. Negative results (LCSCs not present) were determined when analytical results revealed a lead concentration of less than 0.10 mg/cm2, which is below the analytical sensitivity of the XRF measurement methodology. RESULTS Pre-Demolition Asbestos Survey A total of 23 bulk samples for the determination of asbestos content were collected from the subject site on June 13, 2007. Based on the results of the pre-demolition asbestos survey of the subject property and laboratory analytical results, the following materials are considered to be ACMs, as defined by USEPA, and found to contain detectable concentrations of 1% OR GREATER OF ASBESTOS (locations, conditions, and estimated total quantity of materials are found in the Executive Summary): Pajama Drive Reservoir 1. Joint Compound 2. Window Putty 3. Roof Mastic 4. Gaskets Based on the results of the limited asbestos survey of the subject building, the following materials are considered to be 'ACCMs, as defined by Cal/OSHA, and found to contain detectable concentrations of 0.1% OR GREATER, BUT LESS THAN 1% OF ASBESTOS (locations, conditions, and estimated total quantity of materials are found in the Executive Summary): Pajama Drive Reservoir 1. Concrete Seal The individual bulk sampling results and the materials suspected to be asbestos and determined not to contain detectable concentrations of asbestos can be found in the AmeriSci laboratory reports, which are located within Appendix C of this document. Survey Report - Section 2 June 29, 2007 Pajama Drive Reservoir Page 3 CONSULTING ENGINEERS Lead Testing Services A total of 39 XRF measurements for the determination of lead content were collected from the subject site on June 13, 2007. The analytical results for this testing indicate that the components and respective surface coatings did have lead concentrations defining them as LBPs, in accordance with Title 17 of the California Code of Regulations, Section 35001 et. Seq (locations, conditions, and estimated total quantity of materials are found in the Executive Summary): Pa jama Drive Reservoir 1. Green/Wood Doors 2. Green/Wood Door Jambs 3. Green/Wood Door Frames 4. Green/Metal Tank Exterior 5. Green/Metal Doors of Chlorine Meter 6. Green/Metal Overflow Pipe A lead testing orientation map can be found in Appendix B of this document. Individual XRF measurement results and LCSCs can be found in Appendix D of this document. CONCLUSIONS/RECOMMENDATIONS Pre-Demolition Asbestos Survey The results of the pre-demolition asbestos survey indicate that ACMs and ACCMs are present at the Pajama Drive Reservoir, which may be impacted by the impending demolition activities. At no time should the identified ACMs or ACCMs be drilled, cut, sanded, scraped or otherwise disturbed by untrained personnel. These materials should be removed prior to any activities which will impact these materials. Asbestos disturbance and/or removal operations must be conducted by a Cal/OSHA-registered and State licensed asbestos removal contractor. Disturbance and/or abatement operations should be performed under the direct observation of a California Certified Asbestos Consultant or Certified Site Surveillance Technician. Construction activities involving the potential for impacting ACMs should be conducted in accordance with the requirements of Title 8 of the California Code of Regulations, Section 1529 (8 CCR 1529). For abatement activities which will involve the removal of at least 160 square feet, 260 linear feet, or 35 cubic feet of identified friable ACMs and/or regulated ACMs, notification must be made to the San Diego Air Pollution Control District (SDAPCD). Notification to the SDAPCD must be accomplished ten working days prior to the initiation of such activities. For abatement activities which will involve asbestos-related work of at least 100 square or linear feet, written notification must be made to the Cal/OSHA. Notification to the Cal/OSHA must be accomplished 24 hours prior to the initiation of such activities. Survey Report - Section 2 June 29, 2007 Pajama Drive Reservoir Page 4 CONSULTING ENGINEERS Notification to employees and contractors working within the building should be made in accordance with the California Health and Safety Code, Section 25915 et.seq. and Proposition 65. It is the contractor's responsibly to confirm the ACM and ACCM quantities present prior to initiating renovation or demolition activities at the subject building. Should materials similar to those identified in this report, or other forms of suspect ACMs or ACCMs be present or identified, maintenance personnel/contractors should be instructed to immediately cease work activities which may initiate a fiber release episode, and notify the appropriate management personnel. Lead Testing Services The lead testing services revealed that building components with coatings defining them as LBPs and LCSCs are present at the Pajama Drive Reservoir, which may be impacted by the impending demolition activities. At present there is no state or federal regulation requiring mandatory lead removal or abatement prior to disturbance or demolition of structures with identified lead materials. However, there are applicable Cal/OSHA worker protection and training requirements; Cal/EPA waste disposal requirements, Cal/DHS requirements for public and residential buildings, and SB 460 lead hazard regulations that apply to lead-related construction activities, abatement activities and their associated wastes. The following is a brief discussion and summary of applicable regulatory requirements: * Cal/OSHA: Title 8, California Code of Regulation (CCR), Section 1532.1 (8 CCR 1532.1) governs occupational exposure to lead. This regulation requires that prior to initiation of certain activities, referred to as "trigger tasks", workers must be trained, medically evaluated, and properly fitted with respiratory protection, and protective clothing until statistically reliable personal eight-hour time weighted average (TWA) results indicate lead exposure levels below the Personal Exposure Limit (PEL) for each unique task which disturbs lead-based and lead-containing coatings. This process is known as a Negative Exposure Assessment or NEA. If the result of the exposure assessment is above the Action Level (AL) additional monitoring is required and if the result is above the PEL additional exposure monitoring, worker protection (including respirator protection and PPE), training and medical requirements apply. However even where the NEA criteria is met, certain hazard communication training and work practice controls still apply where lead is disturbed. "Trigger tasks" are tasks that are assumed to exceed the PEL pending an exposure assessment and they encompass the majority of construction activities that disturb surface coatings. Examples of "trigger" tasks range from manual paint scraping as a lower expected exposure up to hot work and abrasive blasting as the highest expected exposures, and include any non-listed task that the employer determines may potentially expose employees to lead levels above the AL. NOTE - "OSHA does not consider any method that relies solely on the analysis of bulk materials or surface content of lead (or other toxic material) to be acceptable for safely predicting employee exposure to airborne contaminates. Without air monitoring results or without the benefit of historical or objective data (including air sampling which clearly demonstrates that the employee can not be exposed above the action level during any process, operation, or activity) the analysis of bulk or surface samples can not be used to determine employee exposure." OSHA Standard Interpretation 5/8/2000. Survey Report - Section 2 June 29, 2007 Pajama Drive Reservoir Page 5 CONSULTING ENGINEERS Furthermore, OSHA states that these rules apply to "any detectable concentration of lead" without a specified detection level. Due to the Consumer Product Safety Commission currently allowing paint to contain up to 600 parts per million (ppm) of lead, the variation of lead content due to aging and weathering, and the variation of detection limits associated with both paint chip and XRF analysis, it is recommended that all painted or coated surfaces be treated as potentially containing lead. Clearly, positive analytical results by either method can be used to indicate that detectable lead is present but negative results cannot be interpreted as conclusively demonstrating the absence of lead. Analytical data of bulk paint/coating materials or surface content (by XRF) of lead can be helpful in evaluation of lead-related environmental risks in general but cannot be used to calculate worker exposures and are not a substitute for employee exposure monitoring. As a result of the above, any employee that works around potential lead-based or lead-containing coatings must have HAZCOM training and personal exposure air monitoring is additionally required for employees that disturb such coatings. Significant additional certification, notification, and work practices are required for materials found to be "lead-based". Any welding, cutting or heating of metal surfaces containing surface coatings should be conducted in accordance with 29 CFR 1926.354 and 8 CCR 1537. These regulations require surfaces covered with toxic preservatives, and in enclosed areas, be stripped of all toxic coatings for a distance of at least 4 inches, in all directions, from the area of heat application prior to the initiation of such heat application. Cal/EPA through the Division of Toxic Substance Control (DTSC) regulates disposal of lead hazardous waste (22 CCR Division 4, Chapter 30, Minimum Standards for Management of Hazardous and Extremely Hazardous Wastes). DTSC has issued guidance indicating that architectural debris with intact lead paint is normally expected to be handled as general construction waste. However, waste stream segregation and analysis is still required for all paint or coating debris regardless of if the paint or coating is intact on a building component or not. The resulting wastes may be hazardous under California and federal RCRA standards for lead and therefore require proper handling, packaging, labeling, and transportation under a proper manifest to a permitted hazardous waste storage, treatment and disposal facility. Cal DHS: The Department of Health Services (DHS) has specific requirements (Title 17 Sections 35001 thru 36100 et. al.) for hazard assessment and work in public or residential structures. These regulations require special certifications, work practices, and notification for such activities. Senate Bill 460 (SB 460): An act to amend Section 1941.1 of the Civil Code, and to amend Sections 17961, 17980, and 124130 of, and to add Sections 17920.10, 105251, 105252, 105253, 105254, 105255, 105256, and 105257 to, the Health and Safety Code, relating to lead abatement. This bill allows for fines and criminal penalties to be levied on any person who is found to have performed lead abatement without containment or created a measurable lead hazard based upon current DHS standards. The testing for this determination can be initiated by any local or state building inspector, health department inspector, or other designated state or local official. A determination of a lead hazard is not solely based upon the lead content of the paint or coating and can be the result of the disturbance of such materials with low concentrations of lead. Survey Report - Section 2 June 29, 2007 Pajama Drive Reservoir Page 6 CONSULTING ENGINEERS Written notification to Cal/OSHA must be accomplished should LBP activities involve more than 100 square or 100 linear feet of removal in accordance with the requirements of 8 CCR 1532.1. Proper written notification to Cal/DHS may be required, depending upon the nature of the abatement activity It is the contractor's responsibly to confirm the hazardous material quantities present prior to initiating renovation or demolition activities at the subject building. Should materials similar to those identified in this report, or other forms of suspect hazardous materials be present or identified, maintenance personnel/contractors should be instructed to immediately cease work activities which may initiate a fiber release episode, and notify the appropriate management personnel. Survey Report - Section 2 June 29, 2007 Pajama Drive Reservoir Page 7 APPENDIX A CERTIFICATIONS CONSULTING ENGINEER State of California Division of Occupational Safety and Health Certified Asbestos Consultant Jerry Robert Sherman Name -. .... .. . 97-2324Certification No 02/06/08 ^ State of California Department of Health Services Lead-Related Certificate Expiration Construction Type Certificate STATE OF CALIFORNIA Arnold Schwarzenegger, Governor DEPARTMENT OF INDUSTRIAL RELATIONS DIVISION OF OCCUPATIONAL SAFETY AND HEALTH ASBESTOS CONSULTANT and TRAINER APPROVAL UNIT 2211 Park Towne Circle, Suite 1 Sacramento, CA 95825 Tel: (916) 574-2993 Fax: (916) 483-0572 508173852C Steve G Pitts 1131 Moana Dr San Diego 282 CA 92107 July 31, 2006 Dear Certified Asbestos Consultant or Technician: Enclosed is your certification card. To maintain your certification, please abide by the rules printed on the back of the certification card. Your certification is valid for a period of one year. If you wish to renew your certification, you must apply for renewal at least 60 days before the expiration date shown on your card. [8 CCR 341.15(h)(1)]. Please hold and do not send copies of your required AHERA refresher renewal certificates to our office until you apply for renewal of your certification. Please inform our office at the above address, fax number or actu@dir.ca.gov of any changes in your contact/mailing information within 15 days of the change. Sincerely, Jeff Ferrell Senior Industrial Hygienist JF/ms Attachment: Certification Card cc: File (Renewal - Card Attached Revised 10/13/05) State of California Division of Occupational Safety and Health Certified Asbestos Consultant Steve GPJtfs Name Certification No. Expires This certification was issued by Ihe Division ol MAY / Mr. Steve G. Pitts Winzler & Kelly Consulting Engineers 4180RuffmRoad,#115 San Diego, California 92123 State of California Department of Health Services Lead-Related Certificate Expiration.Construction Type pajeCertificate Inspector/Assessor 05/12/2008 STATE OF CALIFORNIA Arnold Schwarzenegger, Governor DEPARTMENT OF INDUSTRIAL RELATIONS DIVISION OF OCCUPATIONAL SAFETY AND HEALTH ASBESTOS CONSULTANT and f RAINER APPROVAL UNIT 2211 Park Towne Circle, Suite 1 i Sacramento, CA 95825 Tel: (916)574-2993 Fax:(916)483-0572 508173853C Stephen S Reese 4123 Twilight Ridge San Diego 282 July 31, 2006 CA 92130 Dear Certified Asbestos Consultant or Technician: Enclosed is your certification card. To maintain your certification, please abide by the rules printed on the back of the certification card. Your certification is valid for a period of one year. If you wish to renew your certification, you must apply for renewal at least 60 days before the expiration date shown on your card. [8 CCR 341.15(h)(1)]. Please hold and do not send copies of your required AHERA refresher renewal certificates to our office until you apply for renewal of your certification. Please inform our office at the above address, fax number or actu@dir.ca.gov of any changes in your contact/mailing information within 15 days of the change. Jeff Ferrell Senior Industrial Hygienist JF/ms Attachment: Certification Card cc: File (Renewal - Card Attached Revised 10/13/05) State of California Division of Occupational Safety and Health Certified Asbestos Consultant Stephen S Reese Name Certification No.. Expires on 05-3853 09/22/07 Ttiis certification was issued by the Division ol Occupational Safely and Health as authorized by Sections 7180 el seq. ol the Business and Professions Code Mr. Stephen S. Reese Winzler & Kelly Consulting Engineers 4180RuffmRoad,#115 San Diego, California 92123 State of California Department of Health Services Lead-Related Certificate Expiration Construction Type Date Certificate inspector/Assessor 11/25/2007 Sject Monitor 11/25/2007 ID J: 13938 APPENDIX B ASBESTOS SAMPLE LOCATION/LEAD TESTING ORIENTATION MAP CONSULTING ENGINEER CONSULTI N G ENGI NEERS BY: PITTS/SHERMAN REPORT DATE: 06/29/07 CLIENT: CITY OF CARLSBAD 4180 RUFFIN ROAD SUITE 115 SAN DIEGO, CALIFORNIA 92123 PH (858) 244-0440 FAX (858) 244-0441 SUBJECT: ASBESTOS SAMPLE LOCATION / LEAD TESTING ORIENTATION MAP LOCATION: PAJAMA DRIVE RESERVOIR JOB No. 1038207006.77010 SHEET No. 1 of 1 A-6 DO LU Q CO LOCATIONS AND DIRECTIONS ARE APPROXIMATE A . APPROXIMATE LOCATION OF ASBESTOS ROOF SAMPLE • - APPROXIMATE LOCATION OF SAMPLE ANALYZED FOR ASBESTOSXXX SIDE A- APPROXIMATE LOCATION OF SAMPLE ANALYZED FOR ASBESTOS NOT TO SCALE SIDE C APPENDIX C ASBESTOS ANALYTICAL DATA (LABORATORY REPORT) CONSULTING ENGINEERS AmeriSci Los Angeles yi r> 24416 SOUTH MAIN STREET • SUITE 308 r\ MERI O C/ CARSON, CA 90745 TEL: (310) 834-4868 • FAX (310) 834-4772 June 20.2007 Winzler & Kelly Consulting Engineers / San Oi Attn: Steve Reese 4180 Ruffin Road Suite 115 San Diego, CA92123 RE: Winzler & Kelly Consulting Engineers / San Di Job Number 907061365 P.O. #1038207006.77010 1038207006.77010; City Carlsbad; Pajama Dr. Reservoir (Report Amended 6/20/2007) Dear Steve Reese: Enclosed are the results for polarized light microscopy analysis (PLM) of the following Winzler & Kelly Consulting Engineers / San Di samples received at AmeriSci on Thursday, June 14, 2007, for a 24 hour turnaround: A-1. A-2, A-3, A-4. A-5, A-6, A-7, A-8, A-9, A-10, A-11, A-12, A-13, A-14, A-15. A-16. A-17, A-18. A-19, A-20, A-21. A-22, A-23 The 23 samples contained in Ziplock Bags were shipped to AmeriSci via Federal Express. These samples were prepared and analyzed according to the EPA Interim Method (EPA 600/M4-82-020 per 40 CFR 763, subpt F, App. A). The samples were evaluated for homogeneity by low power stereomicroscopy. Asbestos fibers were identified by PLM and dispersion staining through the determination of the required optical properties including: morphology, color, pleochroism, refractive indices, birefringence, extinction and sign of elongation. The required analytical information, analysis results, analyst signature and laboratory identification is contained in the Analyst's Report. This report relates ONLY to the sample analysis expressed as percent asbestos. The CV for this analysis is expected to range from 0.3 to 1.2, depending on the quantity of analyte present. AmeriSci assumes no responsibility for customer supplied data such as "sample type", "location", or "area sampled". This report must not be used to claim product endorsement by AmeriSci, NVLAP or any agency of the U. S. Government. The National Institute of Standards and Technology Accreditation requirements mandate that this report must not be reproduced, except in full without the written approval of the laboratory. This report may contain specific data not covered by NVLAP or ELAP accreditations respectively, if so identified in relevant footnotes. AmeriSci appreciates this opportunity to serve your organization. Please contact us for any further assistance or with any questions. /lary S. David ' Client Services Manager" Boston * Los Angeles • New York • Richmond AMERlSd AmeriSci Los Angeles 24416 S. Main Street, Ste 308 Carson. California 90745 TEL: (310) 834-4868 • FAX: (310) 834-4772 PLM Bulk Asbestos Report Winzler & Kelly Consulting Engineers / San Di Attn: Steve Reese 4180 Ruffin Road Suite 115 San Diego, CA92123 Date Received 06/14/07 Date Examined 06/15/07 AmeriSci Job No. 907061365 P.O.* 1038207006.77010 Page 1 of 5 RE 1038207006.77010; City Carlsbad; Pajama Dr. Reservoir (Report Amended 6/20/2007) Client No. / HGA Lab No. Asbestos Present A-1 907061365-01.1 No A Location: Control Bldg. (Debris) / Drywall / Joint Compound /White Description: White/Brown, Heterogeneous, Fibrous, Drywall / Tape Asbestos Types: Other Material: Cellulose 15 %, Non-fibrous 85 % A-1 A 907061365-01.2 Yes Location: Control Bldg. (Debris) / Drywall / Joint Compound / White Description: Beige, Heterogeneous, Fibrous, Joint Compound Asbestos Types: Chrysotile 6.0 % Other Material: Non-fibrous 94 % Total % Asbestos NAD (by CVES) by Olga K. Katsuk on 06/15/07 6% (by CVES) by Olga K. Katsuk on 06/15/07 A-2 A 907061365-02.1 No Location: Control Bldg. (Debris) / Drywall / Joint Compound / White Description: White/Brown, Heterogeneous, Fibrous, Drywall / Tape Asbestos Types: Other Material: Cellulose 20 %, Non-fibrous 80 % NAD (by CVES) by Olga K. Katsuk on 06/15/07 A-2 A 907061365-02.2 Location: Control Bldg. (Debris) / Drywall / Joint Compound / White Description: Beige, Heterogeneous, Fibrous, Joint Compound Asbestos Types: Chrysotile 6.0 % Other Material: Non-fibrous 94 % 6% (by CVES) by Olga K. Katsuk on 06/15/07 A-3 A 907061365-03.1 No Location: Control Bldg. (Ceiling) / Drywall / Joint Compound / White Description: White/Brown, Heterogeneous, Fibrous, Drywall / Tape Asbestos Types: Other Material: Cellulose 10 %, Non-fibrous 90 % NAD (by CVES) by Olga K. Katsuk on 06/15/07 See Reporting notes on last page AmeriSciJob*: 907061365 Client Name: Winzler & Kelly Consulting Engineers / San Di Page 2 of PLM Bulk Asbestos Report 1038207006.77010; City Carlsbad; Pajama Dr. Reservoir (Report Amended 6/20/2007) Client No. / HGA Lab No. Asbestos Present A-3 907061365-03.2 Yes A Location: Control Bldg. (Ceiling) / Drywall / Joint Compound / White Description: Beige, Heterogeneous, Fibrous, Joint Compound Asbestos Types: Chrysotile 5.0 % Other Material: Non-fibrous 95 % A-4 B 907061365-04 Yes Location: Control Bldg. Window / Window Putty / Gray Description: Grey, Heterogeneous, Non-Fibrous, Cementitious, Bulk Material Asbestos Types: Chrysotile 2.0 % Other Material: Non-fibrous 98 % A-5 B 907061365-05 Yes Location: Control Bldg. Window / Window Putty / Gray Description: Grey, Heterogeneous, Non-Fibrous, Cementitious, Bulk Material Asbestos Types: Chrysotile 2.0 % Other Material: Non-fibrous 98 % A-6 B 907061365-06 Vies Location: Control Bldg. Window / Window Putty / Gray Description: Grey, Heterogeneous, Non-Fibrous, Cementitious, Bulk Material Asbestos Types: Chrysotile 2.0 % Other Material: Non-fibrous 98 % A-7 C 907061365-07 Location: Control Bldg. Scale / Silver Paint / Silver Description: Silver, Homogeneous, Non-Fibrous, Bulk Material Asbestos Types: Other Material: Non-fibrous 100 % Total % Asbestos 5% (by CVES) by Olga K. Katsuk on 06/15/07 2% (by CVES) by Olga K. Katsuk on 06/15/07 2% (by CVES) by Olga K. Katsuk on 06/15/07 2% (by CVES) by Olga K. Katsuk on 06/15/07 NAD (by CVES) by Olga K. Katsuk on 06/15/07 A-8 C 907061365-08 No Location: Control Bldg. Valve / Silver Paint / Silver Description: Silver/Grey, Homogeneous, Non-Fibrous, Bulk Material Asbestos Types: Other Material: Non-fibrous 100 % NAD (by CVES) by Olga K. Katsuk on 06/15/07 See Reporting notes on last page AmeriSci Job #: 907061365 Client Name: Winzler & Kelly Consulting Engineers / San Di Page 3 of PLM Bulk Asbestos Report 1038207006.77010; City Carlsbad; Pajama Dr. Reservoir {Report Amended 6/20/2007) Client No. / HGA Lab No. Asbestos Present A-9 907061365-09 No C Location: Control Bldg. Scale / Silver Paint / Silver Description: Silver, Homogeneous, Non-Fibrous, Bulk Material Asbestos Types: Other Material: Non-fibrous 100 % A-10 D 907061365-10 Wo Location: Control Bldg. Roof / Built Up Roof Mat'l / Blk Description: Black, Heterogeneous, Fibrous, Bulk Material Asbestos Types: Other Material: Cellulose 10 %, Non-fibrous 90 % Total % Asbestos NAD (by CVES) by Olga K. Katsuk on 06/15/07 NAD (by CVES) by Olga K. Katsuk on 06/15/07 A-11 D 907061365-11 Location: Control Bldg. Roof/ Built Up Roof Mat'l / Blk Description: Black, Heterogeneous, Fibrous, Bulk Material Asbestos Types: Other Material: Cellulose 10 %, Non-fibrous 90 % NAD (by CVES) by Olga K. Katsuk on 06/15/07 A-12 D 907061365-12 Wo Location: Control Bldg. Roof / Built Up Roof Mat'l / Blk Description: Black, Heterogeneous, Fibrous, Bulk Material Asbestos Types: Other Material: Cellulose 15 %, Non-fibrous 85 % NAD (by CVES) by Olga K. Katsuk on 06/15/07 A-13 E 907061365-13 Vies Location: Control Bldg. Roof / Roofing Mastic / Gray Description: Grey, Heterogeneous, Fibrous, Bulk Material Asbestos Types: Chrysotile 6.0 % Other Material: Non-fibrous 94 % 6% (by CVES) by Olga K. Katsuk on 06/15/07 A-14 F 907061365-14 Location: Tank Inside / Tank Lining / Blk Description: Black, Homogeneous, Non-Fibrous, Bulk Material Asbestos Types: Other Material: Non-fibrous 100 % NAD (by CVES) by Olga K. Katsuk on 06/15/07 See Reporting notes on last page AmeriSci Job #: 907061365 Client Name: Winzler & Kelly Consulting Engineers / San Di Page 4 of PLM Bulk Asbestos Report 1038207006.77010; City Carlsbad; Pajama Dr. Reservoir (Report Amended 6/20/2007) Client No. / HGA A-15 F Lab No. Asbestos Present 907061365-15 No Location: Tank Inside / Tank Lining / Blk Description: Black, Homogeneous, Non-Fibrous, Bulk Material Asbestos Types: Other Material: Non-fibrous 100 % Total % Asbestos NAD (by CVES) by Olga K. Katsuk on 06/15/07 A-16 F 907061365-16 Location: Tank Inside / Tank Lining / Blk Description: Black, Homogeneous, Non-Fibrous, Bulk Material Asbestos Types: Other Material: Non-fibrous 100 % NAD (by CVES) by Olga K. Katsuk on 06/15/07 A-17 G 907061365-17 Location: Base Of Tank / Tank Gasket / Brn Description: Brown, Homogeneous, Non-Fibrous, Bulk Material Asbestos Types: Other Material: Non-fibrous 100 % NAD (by CVES) by Olga K. Katsuk on 06/15/07 A-18 G 907061365-18 Location: Base Of Tank / Tank Gasket / Brn No Description: Brown, Homogeneous, Non-Fibrous, Bulk Material Asbestos Types: Other Material: Non-fibrous 100 % NAD (by CVES) by Olga K. Katsuk on 06/15/07 A-19 G 907061365-19 Location: Base Of Tank / Tank Gasket / Brn Description: Brown, Homogeneous, Non-Fibrous, Bulk Material Asbestos Types: Other Material: Non-fibrous 100 % NAD (by CVES) by Olga K. Katsuk on 06/15/07 A-20 H 907061365-20 Location: Tank Piping / Flange Gasket / Gray yes Description: Blue, Heterogeneous, Non-Fibrous, Cementitious, Bulk Material Asbestos Types: Chrysotile 40.0 % Other Material: Non-fibrous 60 % 40% (by CVES) by Olga K. Katsuk on 06/15/07 See Reporting notes on last page AmeriSciJob#: 907061365 Client Name: Winzler & Kelly Consulting Engineers / San Di Page 5 of PLM Bulk Asbestos Report 1038207006.77010; City Carlsbad; Pajama Dr. Reservoir (Report Amended 6/20/2007) Client No. / HGA Lab No. Asbestos Present A-21 907061365-21 Yes I Location: Tank Inlet Pipe / Concrete Seal / Gray Description: Beige/Grey, Heterogeneous, Non-Fibrous, Cementitious, Bulk Material Asbestos Types: Chrysotile <1. % Other Material: Non-fibrous 100 % A-22 I 907061365-22 Location: Tank Outlet Pipe / Concrete Ves Description: Beige/Grey, Heterogeneous, Non-Fibrous, Cementitious, Bulk Material Asbestos Types: Chrysotile <1. % Other Material: Non-fibrous 100 % A-23 907061365-23 Location: Tank Over Flow Pipe / Concrete Seal / Gray Description: Beige/Grey, Heterogeneous. Non-Fibrous, Cementitious, Bulk Material Asbestos Types: Chrysotile <1. % Other Material: Non-fibrous 100 % Reporting Notes: Total % Asbestos Trace (<1 %) (by CVES) by Oiga K. Katsuk on 06/15/07 Trace (<1 %) (by CVES) by Olga K. Katsuk on 06/15/07 Trace (<1 %) (by CVES) by Olga K. Katsuk on 06/15/07 ; Date Analyzed: 6/15/2007Analyzed By: Olga K. Katsuk. *NAD = no asbestos detected; Defefctioh Limit <1%; Reporting Limits: CVES = 1%, 400 PtCt = 0.25%, 1000 Pt Ct = 0.1%; NA = not analyzed; NA/PS = not analyze! I / positive stop; PLM (polarized light microscopy) Bulk Asbestos Analysis by EPA 600/M4-82-020 per 40 CFR 763 (N.VLAP Lab #200346-0, CA ELAP lab #2322); Note: PLM is not consistently reliable in detecting asbestos in floor coverings and similar NOB materia[sr-\TEM is currently the only method that can be used to determine if this material can be considered or treatet las non-asbastos-pontaining in New York State (also see EPA Advisory for floor tile, PR 59, 146,38970,8/1/94). NIST approval of the laboratory. Reviewed By: bn requirements/mandate that this report must not be reproduced except in full with the NLY to the items tested. Asbestbs Bulk Sample Log W1NZLER& KELLY CONSULTING ENGINEERS 4180 Ruffln Road. Suite 115 San Diego, CA 92123 Phone: (858) 244-0440 Fax: (858)244-0441 Client:Date:: (J//1/0 7 Vf'Project Number:>.-7?*/.f Collected Bv: Co V W Vf Analytical Method: X PLM V Turnaround Time: SameJDay Sample Receiver: Winzler'STKEIIyConsulting Engineers - 4780 Ruffin fld, #775, San D/ego, CA 92723 CHAIN OF CUSTODY: 3 day 1. (/Title Signature Title Inclusive Dates Inclusive 0afes 3. Signature Title Inclusive Dales Page of Asbestos Bulk Sample Log 7081365 WINZLER& KELLY CONSULTING ENGINEERS 4180 Ruffin Road. Suite 215 San Diego, CA 92123 Phone:(858)244-0440 Fax: (858)244-0441 Client:Date: Location. Collected Bv: Project Number: or SST No: A-tf Con-fr^l r&o£ 0-4- I •in Analytical Method: (PLM^X Turnaround Time: Same Day X34hr? 3 day Sample Keceiver: Winzler & Kelly Consulting Engineers -4180 Ruffin Rd., #115, San Diego, CA 92123 CHAIN QE£JJSTODY: Signature Inclusive Dates Title I inclusive i/i w>Inclusive D; 3. Signature Title Inclusive Dates Asbestos Bulk Sample Log WINZLER& KELLY CONSULTING ENGINEERS 4180 Ruffin Road, Suite 115 San Diego, CA 92123 Phone:(858)244-0440 Fax: (858) 244-044J Date: Location: Collected By:_ Project Number:_ ^D' Analytical Method: (: PjAy Turnaround Time: Same Day / 24hjX 3 day ^-' Sample Receiver: Winzler & Kelly Consulting Engineers - 4780 Ruffin Rd., #115, San Diego, CA 92123 CHAIN OF CUSTODY: ffitle Inclusive Dates Title Inclusive Dates Signature Title Inclusive Dates Page of. APPENDIX D XRF LEAD DATA TABLE CONSULTING ENGINEERS WINZLER AND KELLY CONSULTING ENGINEERS XRF LEAD DATA TABLE CITY OF CARLSBAD - PAJAMA DRIVE mm 2 3 4 5 6 7 a 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 " SHUTTER_CAL CALIBRATE CALIBRATE WALL DOOR DOOR DOORFRAME DOOR JAMB WINDOW WINDOW WALL valve chlorine meter chlorine meter chart recorder turf meter PIPE FLOOR WALL WALL WALL water tank water tank water tank water tank water tank water tank water tank water tank OVERFLOW PIPE ladder PIPE PIPE PIPE TRIM UPPER TRIM UPPER TRIM UPPER TRIM UPPER CONCRETE WOOD WOOD WOOD WOOD METAL METAL CONCRETE METAL METAL METAL METAL METAL METAL CONCRETE CONCRETE CONCRETE CONCRETE METAL METAL METAL METAL METAL METAL METAL METAL METAL METAL METAL METAL METAL METAL METAL METAL METAL INTACT INTACT INTACT INTACT INTACT INTACT INTACT INTACT INTACT INTACT INTACT INTACT INTACT INTACT POOR INTACT INTACT INTACT INTACT INTACT INTACT INTACT INTACT INTACT INTACT INTACT INTACT INTACT INTACT INTACT INTACT INTACT INTACT INTACT INTACT CALIBRATE A A A A A B B B c A A A B C A A C C D B B B D CALIBRATE CALIBRATE CALIBRATE WHITE GREEN GREEN GREEN GREEN GRAY GRAY WHITE SILVER GREEN GREEN GRAY GREEN WHITE GREEN WHITE WHITE WHITE GREEN GREEN GREEN GREEN GREEN GREEN GREEN GREEN GREEN GREEN GREEN GREEN GREEN GREEN GREEN GREEN GREEN control bldg. control bldg. control bldg. control bldg. control bldg. control bldg. control bldg. control bldg. control bldg. control bldg. control bldg. control bldg. control bldg. control bldg. control bldg. control bldg. control bldg. control bldg. reservoir reservoir reservoir reservoir reservoir reservoir reservoir reservoir reservoir reservoir reservoir reservoir reservoir control bldg control bldg control bldg control bldg east east ext. east east east cntr cntr cntr cntr cntr east east east east ext. ext. ext. inside lid outside lid top roof top roof top roof sides sides sides sides sides sides sides sides 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 Positive Positive Positive Negative LBP LBP LBP LBP Negative LCSC Negative Negative LCSC LBP LCSC LCSC Negative LCSC Negative Negative LCSC Negative LBP LBP LBP LBP LBP LCSC LCSC LBP LCSC LCSC LCSC LCSC LCSC Positive Positive Positive 6 1.2 1.2 1.1 0.02 2.2 2.6 3.4 3 0.06 0.15 0.01 0 0.17 7 0.15 0.19 0.03 0.16 0.08 0.05 0.1 0.02 2.6 1.1 1.1 1.5 1 0.9 0.8 1 0.1 0.26 0.4 0.3 0.4 1.1 1.1 1.1 Notes: XRF - X-ray fluorescence spectrum analyzer mg/cm2 -milligrams per square centimeter LCSC - Lead-Containing Surface Coating (8 CCR LBP - Lead-Based Paint (17 CCR 35001 et. seq.), 1532.1) lead present from 0.10 to 0.99 mg/cm2 lead is present at 1 .00 mg/cm2 or greater