EnviroScience
, Inc.
An Environmental Consulting and Industrial Hygiene Company
PATH OF CONSTRCUTION
INSPECTION & SAMPLING REPORT
FOR SUSPECT
ASBESTOS-CONTAINING MATERIALS &
LEAD-CONTAINING PAINTS
AT
CABRILLO COLLEGE — BUILDING 1400
6500 Soquel Drive • Aptos, Ca 95003
1.0
INTRODUCTION
The undersigned representative of EnviroScience, Inc. (ESI), an independent industrial
hygiene (IH) consulting firm representing Cabrillo Community College, hereby presents
the findings of the limited Site inspection and sampling conducted at the location referenced
below (Site).
The purpose of ESI’s limited Site investigation and sampling was to determine the extent of
asbestos-containing materials (ACMs), and lead-containing paints (LCPs) present (if any)
in the path of constrcution of a new HVAC upgrade project at Building 1400 of the
Cmapus.
This survey and sampling does not cover any other buildings on Cmapus, and it’s limited to
path of construction for the upcoming HVAC upgrade project, only.
2.0
GENERAL INFORMATION
SITE LOCATION
Cabrillo College
6500 Soquel Drive • Aptos, CA 95003
BUILDING SURVEYD
Building 1400 — Path of construction
for the new HVAC project
SAMPLING DATE
REPORT DATE
February 24, 2016
March 3, 2016
ON-SITE INSPECTOR
Alfredo Rocha III
PROJECT MANAGER
Hooman Sotoodeh, Ph.D., PE
SIGNATURE
EPA-Certified Building Inspector/Contractor Supervisor
Cal/OSHA-Certified Site Surveillance Technician (#00-2806)
CDPH-Certified Lead Inspector (#20474)
EPA-Certified Building Inspector/Project Designer
Cal/OSHA-Certified Asbestos Consultant (#93-1097)
CDPH-Certified Lead Inspector/Assessor/Project Designer (#1820)
H. Sotoodeh
2220 S. Bascom Avenue • Campbell, California 95008 • (408) 371-4181 • Fax (408) 371-4186
3.0
SITE DESCRIPTION
The Site inspected is Building 1400 building at the Cabrillo College campus in Soquel, CA.
This survey and sampling was limited to the areas of the building, which were going to be
affected by the proposed HVAC upgrade project.
At the time of our Site inspection and sampling, Building 1400 was fully occupied and in
operation. ESI’s inspection & sampling was limited to visible and accessible areas
identified herein, and the findings presented in our report do not apply to unsampled
materials or other parts of the Site, which were inaccessible or not related to the upcoming
HVAC project (i.e., flooring materials, etc.).
The photos below depit the mechanical room and the main level of the building inspected by
ESI.
MECHANICAL ROOM
Photo #1 — Interior view of the mechanical room
(Wallboard joint compound
confirmed to be ACM)
Photo #2 — Interior view of mechanical room
(Wallboard joint compound
confirmed to be ACM)
Photo #3 — Interior view of the mechanical room
Showing bare sheet metal ducts
(Wallboard joint compound
confirmed to be ACM)
Photo #4 — Interior view of the mechanical room
(Wallboard joint compound
confirmed to be ACM)
Limited Site Inspection & Sampling Report for Suspect Asbestos-Containing Materials & Lead-Containing Paints at
Cabrillo College • Building 1400 • Soquel, California
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EnviroScience, Inc.
Photo #5 — Grills and vents being inspected
At the main level of building 1400
Photo #6 — Joint tape on sheet metal
air ducts above ceiling tiles
Photo #7 — Vibration damper material
on certain air ducts above ceiling tiles
Photo #8 — Wallboard joint compound
above ceiling tiles
(Wallboard joint compound
confirmed to be ACM)
Limited Site Inspection & Sampling Report for Suspect Asbestos-Containing Materials & Lead-Containing Paints at
Cabrillo College • Building 1400 • Soquel, California
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EnviroScience, Inc.
4.0
METHODS
4.1
ACM Sample Collection Procedures
Samples of suspect asbestos-containing materials (ACMs) were collected by coring
or by carefully scraping a small portion of a surface. In areas where sampled
material posed a high risk of dust release, a half-face type H respirator equipped
with a HEPA filter was worn by the inspector for respiratory protection. The
sampled material was immediately contained in plastic ziplock bags. The sampling
information was recorded in a bound field
notebook. Samples were then properly
labeled with a unique sample identification
umber, and delivered via overnight to a
NVLAP-certified, independent laboratory
(EMSL Testing, Inc., of San Leandro,
California) for 24-hour RUSH analysis along
with the appropriate chain-of-custody
documentation.
4.2
ACM Sample Analysis Procedures
All ACM samples were analyzed using polarized light microscopy (PLM)
techniques at a state-certified independent laboratory. 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-asbestiform materials was visually estimated.
4.3
Paint Chip Sampling for Lead
Samples of suspect lead-based paints (LBPs) were collected by carefully scraping
approximately 1 gram or about 1 teaspoon-full of the paint from the substrate. The
paint was either peeled from the substrate or
scraped to the substrate, avoiding dust. ESI's onsite 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 sampling information was recorded in a bound
field notebook. The paint samples were then
properly labeled and delivered to the independent
laboratory for analysis along with the appropriate
chain-of-custody documentation.
4.4
LCP Sample Analysis Procedures
Samples of suspect paint were analyzed in accordance with EPA Method 7420,
analysis by flame Atomic Absorption (AA) spectroscopy, 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 wavelength and the absorption of light is directly
proportional to the concentration of atoms in solution.
Limited Site Inspection & Sampling Report for Suspect Asbestos-Containing Materials & Lead-Containing Paints at
Cabrillo College • Building 1400 • Soquel, California
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EnviroScience, Inc.
5.0
ANALYTICAL DATA & RESULTS
5.1
Bulk Samples for Asbestos
Sample
Number
Sampled
Material
Sample
Location
Asbestos
Concentration
Recommendation
MECHANICAL ROOM
(Upper Level)
1400-L1
Drywall joint
compound
E. Wall of
mechanical room
Drywall
Joint Compound
ND*
<1%C***
N/A**
Abate as ACM
Drywall joint
compound
S. Wall of
mechanical room
Drywall
Joint Compound
ND
<1%C
N/A
Abate as ACM
Drywall joint
compound
W. Wall of
mechanical room
Drywall
Joint Compound
ND
<1%C
N/A
Abate as ACM
Vibration
damper
Mechanical room
furnace
Black Damper
Vibration
damper
Mechanical room
air ducts
Black Damper
Air duct
joint tape
Around air ducts of
mechanical room
White Tape
Furnace
tape
Around furnace in
mechanical room
White Tape
Caulking
material
Around furnace of
mechanical room
Gray Caulking
......................................................................................................................................................................................................................
1400-L2
......................................................................................................................................................................................................................
1400-L3
......................................................................................................................................................................................................................
1400-L4
ND
N/A
......................................................................................................................................................................................................................
1400-L5
ND
N/A
......................................................................................................................................................................................................................
1400-L6
ND
N/A
......................................................................................................................................................................................................................
1400-L7
ND
N/A
......................................................................................................................................................................................................................
1400-L8
ND
N/A
ND
N/A
GROUND LEVEL
(around ceiling registers and grills)
1400-L9
Ceiling tile
material
SE side next to
the entry way
White Tile
Vibration
damper
SE side next to
the entry way
White Damper
Ceiling tile
material
Next to the
assistant office
White Tile
Vibration
damper
Next to the
conference room
White Damper
Air duct
joint tape
Around air ducts
conference room
Tan Tape
Drywall joint
compound
Above ceiling tiles
of main classroom
Air duct
joint tape
Around air ducts
NE side ducts
......................................................................................................................................................................................................................
1400-L10
ND
N/A
......................................................................................................................................................................................................................
1400-L11
ND
N/A
......................................................................................................................................................................................................................
1400-L12
ND
N/A
......................................................................................................................................................................................................................
1400-L13
ND
N/A
......................................................................................................................................................................................................................
1400-L14
Joint Compound
Drywall
2%C
ND
Abate as ACM
N/A
ND
N/A
......................................................................................................................................................................................................................
1400-L15
Gray Tape
*
None Detected
* * None Applicable
* * * Chrysotile-type Asbestos
Limited Site Inspection & Sampling Report for Suspect Asbestos-Containing Materials & Lead-Containing Paints at
Cabrillo College • Building 1400 • Soquel, California
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EnviroScience, Inc.
5.1
Bulk Samples for Asbestos
Sample
Number
Sampled
Material
Sample
Location
Asbestos
Concentration
Recommendation
GROUND LEVEL
(around ceiling registers and grills)
1400-L16
Wall
texture
Ceiling of
asst office
Ceiling
tiles
SW side of
main classroom
White Texture
ND*
N/A**
......................................................................................................................................................................................................................
1400-L17
White Tile
ND
N/A
......................................................................................................................................................................................................................
1400-L18
Drywall joint
compound
Ceiling of the
Joint Compound
computer Tech office Drywall
2%C***
ND
Abate as ACM
N/A
......................................................................................................................................................................................................................
1400-L19
Wall
texture
Ceiling of the
White Texture
computer Tech office
ND
N/A
......................................................................................................................................................................................................................
1400-L20
Roofing
material
Roof of
Building 1400
Black Roofing
ND
N/A
*
None Detected
* * None Applicable
* * * Chrysotile-type Asbestos
Limited Site Inspection & Sampling Report for Suspect Asbestos-Containing Materials & Lead-Containing Paints at
Cabrillo College • Building 1400 • Soquel, California
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EnviroScience, Inc.
5.2
Paint Chip Samples for Lead
Sample
Number
Painted Surface
(Color)
Paint
Location
Lead
Concentration
Recommendation
1400-P1
Furnace paint
(Green)
Furnace
in the
mechanical room
0.33 %
or
3,300 ppm*
Treat all interior
surfaces painted
this color as
lead containing
...................................................................................................................................................................................................................
1400-P2
Compressor tank
paint
(Silver)
Air compressor
in the
mechanical room
0.46 %
or
4,600 ppm
Same as 1400-P1
Interior wall
paint
(White)
Interior wall
of the student
assistant office
<0.010 %
or
<LOD**
None
Interior wall
paint
(White)
Interior wall
of the main
classroom
<0.010 %
or
<LOD
None
...................................................................................................................................................................................................................
1400-P3
...................................................................................................................................................................................................................
1400-P4
*
**
Parts Per Million
Limit of Detection
Limited Site Inspection & Sampling Report for Suspect Asbestos-Containing Materials & Lead-Containing Paints at
Cabrillo College • Building 1400 • Soquel, California
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EnviroScience, Inc.
6.0
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 that 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.
Limited Site Inspection & Sampling Report for Suspect Asbestos-Containing Materials & Lead-Containing Paints at
Cabrillo College • Building 1400 • Soquel, California
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EnviroScience, Inc.
7.0
FINDINGS
7.1
Asbestos Containing Materials (ACM)
Based on the analytical findings of the 25 sample layers collected from the
mechanical room and ground level of Building 1400 and analyzed for asbestos, it is
confirmed that the following building material contains asbestos above the 0.1%
limit regulated by Cal/OSHA, and above the 1.0% limit regulated by EPA.
7.1.1
7.2
The wallboard joint compound throughout the entire Building 1400
(below and above ceiling surfaces) contains <1-2% Chrysotile-type
asbestos. All wallboard surfaces should be treated as ACM in this
building.
Lead-Containing Paint (LCPs)
The California Occupational Safety and Health Administration (Cal/OSHA),
considers any paint with any concentration of lead above the limit of detection
(LOD) of the analytical procedure, to be considered as lead-containing paint (LCP).
All construction or renovation work where employees may be occupationally
exposed to LCP shall be conducted in compliance with California Code of
Regulations (CCR), Title 8, Section 1532.1 "Lead in Construction."
Based on the analytical findings of the 4 paint chip samples collected from various
paints throughout Building 1400, and analyzed for lead, it is confirmed that the
following painted surfaces contain lead above the LOD of the analytical procedure,
and are thus considered to be LCP per OSHA’s definition.
7.2.1 The green-colored furnace paint in
the mechanical room of building
1400 contains 3,300 parts per
million (ppm) lead; and
7.2.2
The silver-colored paint on the
compressor tank in the mechanical
room of building 1400 contains
4,600 parts per million (ppm) lead.
Limited Site Inspection & Sampling Report for Suspect Asbestos-Containing Materials & Lead-Containing Paints at
Cabrillo College • Building 1400 • Soquel, California
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EnviroScience, Inc.
8.0
RECOMMENDATIONS
8.1
ACMs
This survey was conducted in anticipation for installation of a new HVAC system in
Building 1400.
If disturbing or removing more than 100 sq. ft. of asbestos-containing material
(even below 1%), the California State License Board (CSLB) requires that the
contractor be licensed as C-22 (Asbestos Abatement), and be registered by DOSH
as an asbestos abatement contractor.
Under the United States Environmental Protection Agency (US EPA)'s National
Emissions Standards for Hazardous Air Pollutants (NESHAP) regulations, all
asbestos-containing materials shall be properly abated and disposed of, prior to
disturbance or demolition.
According to the OSHA Construction Industry Standard for Asbestos (29CFR
1926.1001), and the general industry asbestos standard (29CFR 1019.1001)
workers performing asbestos abatement must be trained, equipped with respirators
and full body protection, and be medically fit to wear respirators. Furthermore, all
removal shall be performed using wet abatement procedures and waste containing
greater than 1% asbestos shall be packaged in accordance with EPA's NESHAP
regulation (40 CFR Parts 61 and 763) and according to California Department of
Health Services (DHS), California Code of Regulations, Title 22, Division 4,
Chapter 30, Section 66699 and Health and Safety Code 25179.3 et. Seq.
During the site inspection, ESI’s field inspector determined that the following
homogeneous material contains asbestos above EPA and OSHA levels.
8.1.1
Wallboard Joint Compound
The compound and textured skim coat applied to the surface of all interior
walls throughout Building 1400 contains <1-2% Chrysotile-type asbestos.
If any wallboard throughout Building 1400 is scheduled for disturbance or cutting
during the upcoming HVAC renovation project, ESI recommends that a Statelicensed and DOSH-registered asbestos abatement contractor perform the removal
and disposal of these ACMs, under proper regulatory guidelines, and under the
supervision of the Owner’s IH consultant.
Limited Site Inspection & Sampling Report for Suspect Asbestos-Containing Materials & Lead-Containing Paints at
Cabrillo College • Building 1400 • Soquel, California
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8.2
LCPs
Any construction-related demolition or cleanup where employees may be
occupationally exposed to lead shall be conducted in compliance with the California
Code of Regulations (CCR), Title 8, Section 1532.1 and 5216 "Lead in
Construction", and in accordance with Federal Occupational Safety and Health
Administration (OSHA) section 29 CFR 1926.62.
In compliance with Cal/OSHA and California Department of Public Health (CDPH)
regulations, ESI requires that an RRP-certified contractor using CDPH-certified
lead workers and supervisors conduct any demolition or debris cleanup activity that
may involve either of the following two lead containing paints:
8.2.1
The green-colored paint on the furnace of the Mechacnical room,
which contains 3,300 ppm lead; and
8.2.2
The silver-colored paint on the compressor tank in the mechanical
room, which contains 4,600 ppm lead.
Any demolition or debris cleanup shall be conducted using wet methods for dust
suppression, and work practices by the CDPH-certified lead personnel shall be such
that the 8-hour time weighted average (TWA) permissible exposure limit (PEL)
shall not exceed 50 µg/m3 . If any worker’s 8-hr TWA exposure exceeds the action
level of 30 µg/m3 , work practices causing elevated lead levels shall cease or be
modified under the directive of the IH consultant.
In addition, the contractor must continue to conduct daily personnel air monitoring,
and institute medical surveillance and training programs. If the Cal-OSHA
permissible exposure level (PEL) of 50 µg/m3 for lead is exceeded, more stringent
and additional requirements such as engineering controls, respiratory protection,
regulated work areas, and warning signs in lead work areas, become effective, as
directed by the IH Consultant.
LBP Waste Disposal
Rags and paint chips shall be treated as hazardous waste if laboratory results
indicate a lead (Pb) concentration of 5 milligrams per liter (mg/L), 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.
Building components with lead-based paint still intact (i.e., not flaking, chipping, or
blistered paint) are categorized as “Architectural Components”, and may be
disposed of as regular construction waste, as long as the paint remains intact.
Extreme care shall be exercised, however, to make sure that the intact paint on these
Architectural Components stay tightly adhered to the substrate. If during packaging,
disposal, or transport, any lead-based paint chips flake off from the Architectural
Component, all such paint chips shall be packaged as stated in the previous
paragraph, the waste properly profiled, and then disposed of.
Limited Site Inspection & Sampling Report for Suspect Asbestos-Containing Materials & Lead-Containing Paints at
Cabrillo College • Building 1400 • Soquel, California
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9.0
LIMITATIONS
This report was prepared solely for the use of our client Cabrillo Community College
and their designated representatives, only. No part of this report shall be copied or used for
any purpose by anyone other than the client, without written consent of ESI. Any reliance
on this report by a third party is at such party's sole risk. The content and conclusion
provided by ESI in this report are based on information collected during its assessment,
which include, but are not limited to visual site inspection and limited sampling and
laboratory testing of suspect ACMs, and our professional judgment based on these
information.
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.
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.
Limited Site Inspection & Sampling Report for Suspect Asbestos-Containing Materials & Lead-Containing Paints at
Cabrillo College • Building 1400 • Soquel, California
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EnviroScience, Inc.
Appendix A
Independent Laboratory
Analytical Results for
Bulk Material Samples
Analyzed for Asbestos Content
(EPA Method 600/R-93-116, Visual Area Estimation)
Limited Site Inspection & Sampling Report for Suspect Asbestos-Containing Materials & Lead-Containing Paints at
Cabrillo College • Building 1400 • Soquel, California
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EnviroScience, Inc.
Limited Site Inspection & Sampling Report for Suspect Asbestos-Containing Materials & Lead-Containing Paints at
Cabrillo College • Building 1400 • Soquel, California
Page 14
EnviroScience, Inc.
Limited Site Inspection & Sampling Report for Suspect Asbestos-Containing Materials & Lead-Containing Paints at
Cabrillo College • Building 1400 • Soquel, California
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EnviroScience, Inc.
Appendix B
Independent Laboratory
Analytical Results for
Paint Chip Samples
Analyzed for Lead Content
(EPA Method 3050B/7420)
Limited Site Inspection & Sampling Report for Suspect Asbestos-Containing Materials & Lead-Containing Paints at
Cabrillo College • Building 1400 • Soquel, California
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EnviroScience, Inc.
Limited Site Inspection & Sampling Report for Suspect Asbestos-Containing Materials & Lead-Containing Paints at
Cabrillo College • Building 1400 • Soquel, California
Page 17
EnviroScience, Inc.
Appendix C
Site Map with Sample Locations
At Cabrillo CollegeBuilding 1500
Limited Site Inspection & Sampling Report for Suspect Asbestos-Containing Materials & Lead-Containing Paints at
Cabrillo College • Building 1400 • Soquel, California
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EnviroScience, Inc.
Limited Site Inspection & Sampling Report for Suspect Asbestos-Containing Materials & Lead-Containing Paints at
Cabrillo College • Building 1400 • Soquel, California
Page 19
EnviroScience, Inc.
Limited Site Inspection & Sampling Report for Suspect Asbestos-Containing Materials & Lead-Containing Paints at
Cabrillo College • Building 1400 • Soquel, California
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EnviroScience, Inc.