ASBESTOS-RELATED DOCUMENT REVIEW of Eight Properties For City of San Leandro

Transcription

1 ASBESTOS-RELATED DOCUMENT REVIEW of Eight Properties For City of San Leandro CASA PERALTA W. ESTUDILLO FIRE STATION NO FARGO STREET FIRE TRAINING CENTER LOLA STREET MULFORD BRANCH LIBRARY AURORA STREET MAIN LIBRARY ESTUDILLO STREET SOUTH BRANCH LIBRARY TH AVENUE POLICE (PUBLIC SAFETY BLDG.) E. 14 TH STREET SOUTH OFFICES E. 14 TH STREET PREPARED FOR: City of San Leandro Public Works Chapman Road San Leandro, California EIS Project No September 17, 2008 PREPARED BY: Marvin H. Snapp Cal/OSHA Certified Asbestos Consultant,

2 TABLE OF CONTENTS EXECUTIVE SUMMARY Page SCOPE OF WORK Page SITE DESCRIPTION Page INVESTIGATIVE METHODS Page FINDINGS OF DOCUMENT REVIEW AND SITE INSPECTIONS Page 9 - Casa Peralta Page 10 - Fire Station No. 13 Page 11 - Fire Training Center Page 12 - Mulford Branch Library Page 13 - Main Library Page 14 - Police / Public Safety Building Page 16 - South Branch Library Page 18 - South Offices Annex Page CONCLUSIONS AND RECOMMENDATIONS Page STATEMENT OF LIMITATIONS Page USER RELIANCE Page REFERENCES Page 33

3 ASBESTOS-RELATED DOCUMENT REVIEW For Eight Properties Owned by the City of San Leandro Public Works EXECUTIVE SUMMARY Environmental Investigation Services (EIS) has completed an asbestos-related document review and site inspections of eight facilities owned by the City of San Leandro, California. The purpose of the work was to assist the City of San Leandro, Public Works Department, in determining the extent of Asbestos-Containing Materials (ACMs) located in the eight facilities in order to bring the municipal facilities into compliance with Federal and State of California asbestos regulations. EIS visited the City of San Leandro properties between August 26 and 28, The eight properties which were the subject of this report are listed below: 1. Casa Peralta W. Estudillo Street 2. Fire Station No Fargo Street 3. Fire Training Center Lola Street 4. Mulford Branch Library Aurora Street 5. Main Library Estudillo Street 6. South Branch Library th Avenue 7. Police (Public Safety Bldg.) E. 14 th Street 8. South Offices E. 14 th Street The assessment of the eight buildings in San Leandro, California, included visual observations of building materials suspected of containing asbestiform minerals and review of asbestos related documents provided to EIS by the City of San Leandro Public Works Department. A representative of EIS, Mr. Marvin Snapp, a Cal/OSHA Certified Asbestos Consultant ( ), visited each of the eight properties to inspect them for asbestos-containing materials (ACM) that were listed in the documents for each of the eight properties. A list of the asbestos documents provided to EIS for review is listed in Section 4.0 of this report on the summary pages for each site inspected. Conclusions and Recommendations are provided in Section 5.0 of this report. Asbestos-Containing Materials (ACM) had been identified at each of the eight target properties during previous asbestos inspections conducted between 1992 and Since the initial asbestos surveys were conducted on the buildings in the 1990s, some of the properties have undergone extensive renovations with all, or most of their ACMs removed. Most of the asbestos documents provided to EIS are between eight to sixteen years old and some of the information provided in them was outdated from the actual conditions currently existing at the properties. 1

4 The documents for three of the properties inspected were generally current and complete in the identification of ACMs. These were: 1. Casa Peralta W. Estudillo Street 2. Fire Station No Fargo Street 3. Fire Training Center Lola Street The documents for these three facilities provided to EIS showed the ACMs identified in the original reports are still located in these facilities and generally in good condition. One asbestoscontaining material located at Casa Peralta, a grey duct wrap on heating ducts in the basement exhibited areas of damage which classify the duct wrap as in fair condition. EIS recommends that the damaged area of the grey duct wrap in the basement of Casa Peralta be repaired as soon as possible. As the ducts are located approximately six feet above the basement floor, they could be inadvertently damaged by building personnel working in the basement, thus creating an asbestos exposure incident. Entrance into the basement of Casa Peralta should be limited and controlled until the damaged duct wrap has been repaired, or until the duct wrap has been removed. The other recommendation for these three facilities is to include the identified ACMs in an asbestos Operations and Maintenance (O&M) Program to be developed for the facilities. The asbestos O&M Program is designed to provide the tools necessary to manage ACM within the facilities, while protecting the health and safety of facility personnel and occupants while complying with applicable governmental regulations. Key aspects of the O&M plan include: A. Information regarding the presence, location and quantity of ACM within the facility. B. Means of communication to ensure the health and safety of employees and facilityrelated personnel, and the methods used to communicate the presence, location and quantity of ACM within the facility. C. Responsibilities for compliance with this program. D. Work practices and procedures, including the Standard Work Practices and Procedures, that allow for renovation, construction or emergency maintenance to be performed safely without exposing employees, building occupants, or the public to airborne asbestos fibers. E. City policy for the treatment of installed ACM within the various facilities. F. Training requirements for those who may have contact with or may disturb ACM. G. Recordkeeping requirements and the chain of command for recordkeeping and reporting. 2

5 The documents for the other five properties were generally outdated and contained insufficient information for the proper recommendations for the long term management of any ACMs located in these facilities. These five facilities are as follows: 4. Mulford Branch Library Aurora Street 5. Main Library Estudillo Street 6. South Branch Library th Avenue 7. Police (Public Safety Bldg.) E. 14 th Street 8. South Offices E. 14 th Street EIS could not confirm the presence of ACM identified in the previous ACM documents in these five facilities. The asbestos documentation for these five facilities date from , making these reports between years old. The Main Library building was reported to have been completely renovated in the mid to late 1990s, with the building demolished down to its structural framing and then the new library built over the old library s structural framing. Several asbestos abatement documents provided for the Main Library building indicate that most of the originally identified ACMs had been abated prior to the renovation of this structure. Two of the other buildings, the Public Safety Building and the South Offices, also appear to have been abated of most of the ACMs identified in the 1992/93 ACM reports. Verbal information provided to EIS on these buildings indicated that they had also undergone some level of renovation/remodel in the mid-to-late 1990s. EIS could not locate the ACMs identified in the original asbestos survey reports for these two buildings. EIS did observe suspect ACMs in all five of the above-referenced buildings that were not identified in the provided ACM survey/abatement documents. In order to provide the proper recommendations for the management of ACMs in these five facilities, it is first necessary to determine the extent of ACMs remaining in these buildings, and if ACMs still exist in all five facilities. One of these buildings, the Main Library, appears to have had all of the original ACMs removed prior to renovation, but it is still possible that some of the new building materials contain asbestos. The Public Safety Building and the South Offices, also appear to have had various levels of asbestos abatement performed in the past, but no asbestos abatement reports were available for review for either of these buildings. The other two branch library buildings, Mulford and South Branch, appear to have had only partial asbestos survey conducted on them. Therefore, information as to what ACMs are actually present in these two buildings is incomplete. 3

6 EIS recommends that new asbestos surveys be conducted on the following five buildings in order to determine if ACMs are currently present in these facilities. 4. Mulford Branch Library Aurora Street 5. Main Library Estudillo Street 6. South Branch Library th Avenue 7. Police (Public Safety Bldg.) E. 14 th Street 8. South Offices E. 14 th Street Once asbestos surveys have been completed for these facilities, then further decisions can be made with regards to the proper management decisions for any identified ACMs. If the asbestos survey does not identify any ACMs in a building then that facility and its occupants are not subject to asbestos regulations. General Recommendations In addition to the specific recommendations provided for each of the eight target properties provided previously, EIS makes the following general recommendation concerning the management of asbestos-containing materials by the City of San Leandro. Asbestos Awareness Training is required for city employees whose work activities may contact asbestos containing material (ACMs) or presumed asbestos containing material (PACM) but do not disturb the ACM or PACM during their work activities. This training consists of information regarding asbestos and its various uses and forms. Training also includes information on the health effects associated with asbestos exposure. The training will provide employees with the location of Operations and Maintenance (O&M) plan and name and contact information of the person designated to carry out general responsibilities for ACMs located in City of San Leandro facilities. Asbestos Awareness training does not train employees to work with ACMs or to wear respiratory or personal protection equipment. Asbestos Awareness training provides employees with a basic understanding of the dangers of asbestos, asbestos regulations, and how to identify a potential asbestos exposure situation and who to contact is such a situation. 4

7 1.0 SCOPE OF WORK EIS conducted an asbestos-related document review for eight properties owned by the City of San Leandro, California. The environmental hazard review and site inspection focused on asbestos-containing materials (ACMs). The eight buildings (facilities) included in the document review and inspections are identified as follows: 1. Casa Peralta W. Estudillo Street 2. Fire Station No Fargo Street 3. Fire Training Center Lola Street 4. Mulford Branch Library Aurora Street 5. Main Library Estudillo Street 6. South Branch Library th Avenue 7. Police (Public Safety Bldg.) E. 14 th Street 8. South Offices E. 14 th Street The purpose of this work was to assist the City of San Leandro in determining the extent of Asbestos-Containing Materials (ACM) existing in the above-referenced structures in order to bring San Leandro municipal facilities into compliance with Federal and State asbestos regulations. Two of the primary asbestos regulations impacting the City of San Leandro are: 1. California Title 8, Section 5208, General Industry Safety Order (GISO) for Asbestos, Cal/OSHA (Occupational Safety Health Administration) - Covers all employees in the State of California not working in either the construction or shipyard industries. 2. California Health and Safety Code, Section Generically known as the Asbestos Notification Act. - Outlines requirements and responsibilities of buildings owners/management with respect to managing asbestos materials in their buildings. Primarily covers identification of asbestos materials, notification and training requirements to successfully manage the asbestos materials in a building. Description of Work 1. Review all asbestos-related documents/reports for the above-referenced properties provided by the City of San Leandro, to determine the compliance with current asbestos regulations for the stated buildings. 2. After review of the available asbestos documents, physically inspect each stated facility to correlate the information provided in the asbestos documents with the actual conditions existing at each facility. 3. Identify by visual observation, suspect ACMs such as, wall and ceiling materials, duct wrap, pipe wrap, resilient floor coverings, thermal system insulation (TSI), and other suspect building materials. 5

8 4. No physical sampling of suspect ACMs was included in the scope of work for this phase of the project. 5. Assess the physical condition of each potential ACM. 6. Provide client with a written report for the surveyed structures commenting on the following: Description of the structures surveyed Inadequacies in current asbestos-related documentation in relationship to existing conditions at the sites Recommendations for each facility in order to bring the City of San Leandro into compliance with applicable and current asbestos regulations 2.0 SITE DESCRIPTION The properties that are the subject of this report are identified as follows: 1. Casa Peralta W. Estudillo Street: Historic house built circa Two-story wood-frame building with basement. Greater than 3,000 square feet in size. 2. Fire Station No Fargo Street: Single-story wood-frame structure built prior to Approximately 4,000 to 5,000 square feet in size. 3. Fire Training Center Lola Street: House on site. Constructed prior to Single-story wood frame structure. Concrete fire training tower not included in survey. 4. Mulford Branch Library Aurora Street: Pre-1980 building. Single-story, wood-frame building approximately 1,200 square feet in size. 5. Main Library Estudillo Street: Pre-1970 structure for original building. Original building demolished down to structural framing in mid-1990s and new two-story structure built around old library building. Concrete and steel structure. Greater than 15,000 square feet in size. 6

9 6. Police (Public Safety Bldg.) E. 14 th Street: Built prior to 1975 of concrete, steel and wood framing. Single-story with basement. Limited renovation in mid-1990s. Approximately 10,000 square feet in size. Motor barn at back of police station is a single-story wood-frame with stucco siding. Built pre-1960 and approximately 1,200 square feet in size. 7. South Branch Library th Avenue: A converted residential house of wood-frame construction. Single-story with no basement. Built prior to 1960 and approximately 1,100 square feet in size. 8. South Offices E. 14 th Street: The south annex was constructed prior to It is constructed of concrete framing and masonry block walls. Approximately 7,000 to 9,000 square feet in size. 7

10 3.0. INVESTIGATIVE METHODS 3.1 ACM Inspection Methodology Inspection Protocol For the asbestos visual inspection, EIS personnel walked through the interior and exterior of the subject building, identifying all suspect asbestos-containing materials (ACM). Building materials were grouped into homogeneous categories based on similar characteristics of color and texture. A homogeneous category contains friable or non-friable materials that are uniform in texture and color and appear identical in every respect. Materials installed at different times belong to different homogeneous categories. If there was any reason to suspect that materials might be different even though they appeared uniform, materials were then assigned to a different homogeneous category. This inspection strategy was modeled after the recommended procedures of the Asbestos Hazard Emergency Response Act of 1987 (AHERA) and the EPA guidance document, Asbestos in Buildings: Simplified Sampling Scheme for Friable Surfacing Materials (EPA 560/ a, 11/85). This inspection was a visual survey only, designed to correlate results from previous asbestosrelated documents to current building conditions. No sampling of ACM was performed for this project. Only visual observations were included in this scope of work for this project. Once all suspect ACM had been categorized, EIS visually inspected the suspect asbestos-containing materials. Laboratory Analytical Methods Although no physical asbestos bulk sampling or laboratory analysis was performed for this project, the following describes the procedures and techniques utilized in bulk asbestos sampling. Laboratory analysis of the suspect ACM samples is typically performed using Polarized Light Microscopy with Dispersion Staining (PLM/DS) in accordance with the U.S. EPA Method for the Determination of Asbestos in Bulk Building Materials (EPA-600/R-93/116, July 1993). Percentage estimates of each material component are based upon the analyst's best judgment following PLM/DS analysis and examination with a stereoscope. ACM samples are collected and delivered under chain-of-custody protocol to the appropriately certified asbestos testing laboratory for asbestos content analysis by Polarized Light Microscopy. The U.S. EPA guidelines for asbestos sample analysis state that a building material is considered positive for asbestos when at least one sample of each homogeneous material is identified as containing greater than one-percent (1%) asbestos by weight. The State of California - Occupational Safety and Health Administration (Cal-OSHA) classifies building materials as asbestos-containing construction materials (ACCM) when the materials are found to contain asbestos in quantities of one-tenth of one-percent (0.1%) or greater by weight. Gross characteristics are observed and described under low magnification. Each sample component is then mounted on a microscope slide with refractive index oils. The slides are 8

11 examined for presence, type, and concentration of asbestos minerals. Results are reported as a percent (%) range of total asbestos present. Sample concentrations are also reported as % asbestos by type. Other non-asbestos materials may also be identified. Reported results are a visual estimate by area of asbestos concentration. Results for heterogeneous samples examined by component are reported as a composite. The lower limit of reliable detection for this method is 1%. Samples which contain more than 1% asbestos are reported in 1% ranges. Samples which contain asbestos in concentrations lower than the one percent are reported as <1%. Samples in which no asbestos is observed are reported as None Detected (ND). NOTE: When "None Detected" appears on a report, it means that asbestos was not observed and that, if present, it exists in concentrations less than the limit of reliable detection (<1%) and/or fiber dimensions too small for accurate optical microscopic resolution. Reported results for similar samples may vary due to lack of sample homogeneity, differing collection methods and/or analyst variability. 4.0 FINDINGS OF DOCUMENT REVIEW AND SITE INSPECTIONS Eight properties were included in the document review and site inspections for this report. A representative of EIS, Mr. Marvin Snapp, a Cal/OSHA Certified Asbestos Consultant ( ), visited each of the eight properties to inspect them for suspect asbestos-containing materials (ACM) that were listed in the documents for each of the eight properties. The properties visited are listed below, followed by a discussion of the findings for each property on the following pages. 1. Casa Peralta W. Estudillo Street 2. Fire Station No Fargo Street 3. Fire Training Center Lola Street 4. Mulford Branch Library Aurora Street 5. Main Library Estudillo Street 6. South Branch Library th Avenue 7. Police (Public Safety Bldg.) E. 14 th Street 8. South Offices E. 14 th Street 9

12 1. CASA PERALTA W. ESTUDILLO STREET Documents Reviewed: IHI ACM Survey & Assessment Report, September 17, 1993 ACMs Identified in Previous Reports: - Brick pattern sheet vinyl, Main floor hall, 15 sf, 60% Chrysotile (C) - Lt. Brown sheet vinyl, Kitchen floor, 200 sf, 70% C - Composite roof between church and Main house, 700 sf, 18% C - Roofing felts beneath shake roof on main building, Quantity unknown, 40% C - Grey TSI duct wrap on heat registers & HVAC ducts in attic & basement, 1,200 sf, 75% C Suspect ACMs Identified by EIS: No additional suspect ACMs identified. Observations and Comments: All of the identified ACMs listed in the IHI report from September 1993 were observed to be present at the site. The majority of the identified ACMs appeared to be maintained in good condition. The IHI report appears accurate for this property which included the Main House only. EIS observed damage to the TSI duct wrap on ducts in the basement. This material displayed damage in various locations and should be listed as in fair condition. Recommendations: Casa Peralta is a historic building that was constructed circa 1900, a time when asbestos was used in many building products. The most immediate recommendation for Casa Peralta is to have the exposed HVAC duct wrap in the basement repaired. This issue should receive immediate attention as the ducts in the basement are approximately six feet above the floor and could easily be damaged by building personnel. Repair should be performed by a licensed asbestos abatement contractor licensed to perform such work in California. The identified ACM in Casa Peralta should be included in an asbestos Operations and Maintenance (O&M) Program which is a set of guidelines and practices designed to safely manage the building s ACM in-place until it is removed. 10

13 2. FIRE STATION No FARGO STREET Documents Reviewed: - IHI ACM Survey & Assessment Report, September 10, Micro Analytical Asbestos Laboratory Report, April 1999 ACMs Identified in Previous Reports: 1993 IHI Report: - 12 x 12 brown floor tile/mastic, 700 sf, 20% C - Roofing Materials (shingles), 1,400 sf, 35% C - Roof flashing, Quantity unknown, 30% C 1999 Micro Analytical Report: - Fire Door, 20% C Suspect ACMs Identified by EIS: - Exterior stucco siding The following suspect ACMs had been sampled and found not to contain asbestos in the April 1999 Micro Analytical Laboratory Report: - Interior sheetrock and joint compound - Interior wall plaster - Texturing on interior sheetrock surfaces Observations and Comments: Fire Station 13 was constructed prior to 1960 when asbestos was used in many manufactured building products. The 1993 asbestos survey report and 1999 Asbestos Laboratory report identified all but one suspect ACM at Fire Station 13. This suspect ACM is the exterior stucco siding which may contain asbestos. The stucco remains a suspect ACM until such time as proven not to be an asbestos-containing material by laboratory analysis. Since the IHI survey report was performed 15 years prior to EIS site visit, it is possible that remodeling/renovations of the fire station may have changed conditions from the 1993 report. Recommendations: Fire Station No.13 was constructed pre As there are ACMs present in this structure, it is recommended that the building s confirmed ACMs be included in an asbestos Operations and Maintenance (O&M) program which is a document with guidelines and practices designed to safely manage the building s ACM in-place until such time as they are removed. 11

14 3. FIRE TRAINING CENTER LOLA STREET Documents Reviewed: - IHI Hazardous Materials Survey dated September 12, 2000 ACMs Identified in Previous Reports: - Sheetrock and joint compound, Composite result - <1% C, 910 sf, joint compound - 1-3% C, joint tape - 2-5% C - 9x9 Gold & brown floor tile, 96 sf, 10-20% C - Transite flue, 12 linear feet (lf), 10-15% Crocidolite (Cr) asbestos, 5-10% C - Penetration sealants on roof, 1-2 sf, 10-15% Cr Suspect ACMs Identified by EIS: No additional suspect ACMs identified. Observations and Comments: The IHI asbestos survey report for the Fire Training is fairly recent (2000) and adequately identified suspect ACMs in this building. The ACMs identified by IHI were observed by EIS and all were observed to be in fair to good condition. Recommendations: The Fire Training Center main building is a converted house that appears to have been constructed pre As there are ACMs present in this structure, it is recommended that the building s confirmed ACMs be included in an asbestos Operations and Maintenance (O&M) program which is a document with guidelines and practices designed to safely manage the building s ACM inplace until such time as it is removed. 12

15 4. MULFORD BRANCH LIBRARY AURORA DRIVE Documents Reviewed: - Laboratory Results dated April IHI one page inspection sheet dated January 9, 1992 ACMs Identified in Previous Reports: - Yellow square dotted linoleum, 30-35% C in linoleum backing - Joint tape compound, <1% C - Floor tile & mastic, 18% C in tile, 10% C in mastic Suspect ACMs Identified by EIS: - Yellow sheet vinyl in restroom (description does not match yellow linoleum identified in IHI report) - Roofing materials - Floor tile/mastic beneath carpet - Sheetrock (drywall). Only drywall joint tape compound was previously tested. Observations and Comments: The Mulford Branch Library is a pre-1980 structure. The exact date of construction is unknown. No full asbestos survey report for this building was provided to EIS. The only asbestos documents available for review were a laboratory report and a one page inspection report. Yellow sheet vinyl observed by EIS in the restroom and storeroom of the Mulford Branch Library did not match the description of the yellow linoleum with asbestos identified by IHI in Suspect ACMs such as sheetrock, joint compound, and roofing materials were observed in this building. The extent of ACMs at the Mulford Branch Library is currently unknown. Recommendations: EIS recommends an asbestos survey be conducted on the Mulford Branch Library in order to determine if ACMs are present. Once an asbestos survey has been performed, then further decisions regarding the management of any ACMs can be made, if they are present. 13

16 5. MAIN LIBRARY ESTUDILLO STREET Documents Reviewed: - IHI two-page ACM Inspection Letter dated March 8, IHI ACM Abatement Specifications dated October 12, IHI ACM Abatement Report dated April 13, IHI ACM Survey/Assessment Report dated September 14, IHI ACM Abatement Report dated April 29, 1994 ACMs Identified in Previous Reports: - TSI (pipe insulation) on elbows in roof penthouse, 10% C, 1% Amosite (A) - 9 x 9 floor tiles/mastic on 1 st and 2 nd floors, Tile: 7% C, Mastic: 3-5% C - 12 x12 brown floor tile in storage, kitchen and Estudillo Room, >1% C - Composite Roofing, Upper Roof, 20% C ACMs Identified as Removed in Abatement Reports: - April 1993, ACM Abatement Report by IHI - Removal of TSI as rectangular flue insulation in the Boiler Room area - TSI as pipe elbow and joint insulation in Boiler Room area - TSI pipe runs, elbows and valves as insulation in Chiller area - April 1994, ACM Abatement Report by IHI - Removal of 1,458 square feet of 9"x9" vinyl asbestos floor tile and mastic in southeast mezzanine Suspect ACMs Observed by EIS: - Sheetrock and joint compound - 2 x 2 suspended ceiling tiles - 12 x 12 floor tiles - 2 x 4 suspended ceiling tiles Observations and Comments: The original Main Library building was constructed before According to Mr. Glen Contreras, City of San Leandro Maintenance Supervisor, the Main Library was rebuilt in the mid to late 1990s. Mr. Contreras stated that the original library structure was taken down to its structural framing and then the new library built around the original structure. The new library includes additional space and is larger than the original structure. 14

17 The suspect ACMs EIS observed within the Main Library did not correspond with the ACMs identified in the previous asbestos inspection or abatement reports. Several of the documents provided to EIS were asbestos abatement reports that documented the removal of ACMs in the early to mid 1990s. This corresponds with EIS observations that none of the current building materials have been tested for asbestos content. It appears that most of the ACMs in the original library structure had been removed prior to the remodel of the Main Library building, but it is unknown if the replacement building materials contain asbestos or not. Without written documentation (either manufacturers documentation or laboratory testing results) stating that none of the replacement buildings contain asbestos, they are classified as suspect ACMs under current U.S. EPA and Cal/OSHA asbestos regulations. Recommendations: EIS recommends an asbestos survey be conducted on the San Leandro Main Library in order to determine if ACMs are present. Once an asbestos survey has been performed, then further decisions regarding the management of any ACMs can be made. 15

18 6. POLICE STATION (PUBLIC SAFETY BUILDING) EAST 14 TH STREET Documents Reviewed: - Three page IHI Asbestos Inspection Report dated January 7, 1992 ACMs Identified in Previous Reports: - TSI as pipe insulation on pipe runs & fittings (in basement and above drop-in ceilings) - 9"x9" floor tile throughout building Suspect ACMs observed by EIS: - 2' x 4' suspended ceiling tiles - Sheetrock and joint compound walls - Vinyl sheet flooring - 12"x 12" grey vinyl floor tiles and mastic - Exterior stucco siding There was no information listed for these materials observed at the Public Safety Building by EIS. Observations and Comments: EIS did not observe either the TSI on heating pipes, or the 9"x9" floor tile in the building that was identified as being in the building in the 1992 ACM report. However, EIS did observe many suspect ACMs that were not listed in the 1992 IHI Asbestos Inspection. Mr. Glen Contreras, San Leandro Maintenance Supervisor, stated that he recalled that the Public Safety Building had been remodeled in the mid to late 1990s. From the information provided in the 1992 IHI Asbestos Inspection and the conditions as observed by EIS at the Public Safety Building in August 2008, it is unknown if ACMs are currently present in this building. Motor Barn - A single-story, wood-frame garage structure is located behind the Public Safety building that is used to garage police vehicles. This structure was built prior to 1960 and is approximately 1,200 square feet in size. There was no mention of this structure in the IHI asbestos inspection documents. Suspect ACMs observed by EIS included stucco on the exterior of the building. Recommendations: It is EIS opinion that the building was probably abated of the ACMs identified by IHI in 1992 during the remodel in the mid to late1990s. However, there were no asbestos abatement reports or other documentation for the Public Safety Building made available to EIS to confirm this. To identify if any ACMs are currently located in the Public Safety Building, EIS recommends an asbestos survey be conducted in order to determine if ACMs are present. Once an asbestos 16

19 survey has been performed, further decisions regarding the management of any ACMs can be made, if they are present. 17

20 7. SOUTH BRANCH LIBRARY TH AVENUE Documents Reviewed: - IHI Asbestos Survey/Assessment Report dated August 24, 1993 ACMs Identified in Previous Reports: - Joint compound on west wall, 2% C - 12x12 beige floor tile/mastic. Tile: 15% C, Mastic: 10% C - HVAC vibration damper, 60% C Suspect ACMs Identified by EIS: - 1' x 1' white acoustic ceiling tiles inside library (No sample results) Observations and Comments: ACMs were identified in the South Branch Library by IHI in 1993 as drywall joint compound, 12"x 12" beige floor tile & mastic, and in an HVAC vibration damper in the attic. One suspect ACM was observed by EIS which was a 1'x1' white ceiling tile that was not included in the previous IHI ACM survey report. The South Branch Library building is a converted house that is now used for the library. The original date of construction is pre There was carpet on the floor of the library covering the floor, therefore it is unknown if the beige floor tile identified by IHI in 1993 remains in the building. It was unclear if any renovations had occurred at the South Branch Library since the date of the IHI ACM Survey in Recommendations: EIS recommends an asbestos survey be conducted on the South Branch Library in order to determine if the previously confirmed ACMs are still present. Once an asbestos survey has been performed, further decisions regarding the management of any ACMs can be made, if they are present. 18

21 8. SOUTH OFFICES EAST 14 TH STREET Documents Reviewed: - Two page IHI Asbestos Inspection Report dated January 9, IHI Roofing Material Sampling Report dated November IHI Asbestos Survey/Assessment Report dated August 24, 1993 ACMs Identified in Previous Reports: - Floor tile in supervisor s office, Quantity unknown, 5% C - Floor tile in conference room, Quantity unknown, 5% C - 9 x 9 white floor tile/mastic in conference room, Quantity unknown. Tile: 5% C, Mastic: 5% C - 12 x 12 white floor tile/mastic at rear entrance, Quantity unknown. Tile: 15% C, Mastic: 8% C - 9 x 9 grey floor tile/mastic in theatre & office, Quantity unknown. Tile: 8% C, Mastic: 10% C - Joint compound in office. No quantity listed. 1.2% C - Joint compound at wall corner near jail hall. 2% C - Roof flashing material, 1-2% C Suspect ACMs Observed by EIS: - 2'x 4' suspended ceiling tiles - Sheetrock and joint compound walls - Tar and gravel roof covering materials - Penetration mastics on roof Observations and Comments: EIS observed several suspect ACMs that were not listed in the IHI ACM survey report. These are listed above. The South Offices appear to have been constructed between 1960 and EIS did not observe the ACMs identified in the IHI ACM survey/inspection report written in the early 1990s. Mr. Glen Contreras, City of San Leandro Maintenance Supervisor, told EIS that the building was remodeled in the mid to late 1990s. If the building was abated during a previous remodel/renovation, this would explain why none of the ACMs identified by IHI were observed in the building by EIS. Recommendations: It is EIS opinion that the building was most likely abated of the ACMs identified by IHI in their asbestos survey reports from the early 1990s. However, there were no asbestos abatement reports or other written documentation for the South Offices made available to EIS to confirm this. 19

22 To identify if any ACMs are located in the South Offices, EIS recommends an asbestos survey be conducted in order to determine if ACMs are present or not. Once an asbestos survey has been performed, further decisions regarding the management of any ACMs can be made, if they are present. 20

23 5.0 CONCLUSIONS AND RECOMMENDATIONS EIS reviewed asbestos-related documents for each of the eight properties inspected for this project. The purpose of the document review and site inspections was to correlate the findings and results from the previous asbestos documents with the current conditions that exist at each of the eight target properties as of the date of this report. The City of San Leandro Public Works Department provided EIS with all available asbestos documents relating to each of the eight properties listed below: 1. Casa Peralta W. Estudillo Street 2. Fire Station No Fargo Street 3. Fire Training Center Lola Street 4. Mulford Branch Library Aurora Street 5. Main Library Estudillo Street 6. South Branch Library th Avenue 7. Police (Public Safety Bldg.) E. 14 th Street 8. South Offices E. 14 th Street Asbestos-Containing Materials (ACMs) had been identified at each of the eight target properties during previous asbestos inspections conducted between 1992 and Since the initial asbestos surveys were conducted on the buildings in the 1990s, some of the properties have undergone extensive renovations. Most of the asbestos documents provided to EIS are between eight and sixteen years old and the information in them outdated from current conditions at the properties. A primary purpose of this project was to identify what changes had occurred at each of the eight properties with respect to ACMs. Another reason for identifying the changes in the current status of the eight properties ACMs was to assist the City of San Leandro to bring their municipal facilities into compliance with current Federal and State asbestos regulations. Asbestos-containing materials (ACMs) are regulated by several different Federal and State of California regulatory agencies. At the federal level, the management of ACMs is primarily controlled by the U.S. Environmental Protection Agency (EPA) under its National Emission Standards for Hazardous Air Pollutants (NESHAPs). NESHAPs regulations are administered and enforced in the San Francisco Bay area by the local Bay Area Air Quality Management District (BAAQMD). The U.S. EPA requires that all friable ACMs or non-friable ACMs that could become friable to be removed from buildings prior to any disturbance of the ACMs by remodel or demolition activities that could damage them. Friable ACMs are those that can be pulverized, crumbled or otherwise broken up by using hand or finger pressure when dry. Federal EPA defines friable ACM as any friable material containing more than one percent (1%) asbestos by weight. 21

24 The other primary agency enforcing asbestos regulations in California is Cal/OSHA. Cal/OSHA enforces their asbestos regulations for all employees in the State of California under Title 8, Section 5208, General Industry Safety Order (GISO) for asbestos. This regulation covers all employees in the State of California not working in either the construction or shipyard industries. Cal/OSHA asbestos regulations differ from federal EPA by considering all manufactured building materials containing greater than one-tenth of one percent (0.1%) asbestos to be treated as Asbestos Containing Construction Materials (ACCMs). Another regulation impacting buildings in California is California Health and Safety Code, Section , generically known as the Asbestos Notification Act. This regulation outlines requirements and responsibilities of building owners/management with respect to managing asbestos materials in their buildings. The Act primarily covers identification of asbestos materials, notification and training requirements to successfully manage the asbestos materials in a building. The conclusions and recommendations reached by EIS are presented below: Casa Peralta: EIS observed the following confirmed ACMs identified at Casa Peralta: Confirmed ACMs (Observed by EIS) - Brick pattern sheet vinyl, Main floor hall, 15 sf, 60% Chrysotile (C) - Light Brown sheet vinyl, Kitchen floor, 200 sf, 70% C - Composite roof between church and Main house, 700 sf, 18% C - Roofing felts beneath shake roof on main building, Quantity unknown, 40% C - Grey TSI duct wrap on heat registers and HVAC ducts in attic and basement, 1,200 sf, 75% C All of the above-referenced ACMs were observed at Casa Peralta by EIS. Most were observed to be in good condition with the exception of the grey TSI duct wrap on HVAC ducts in the basement. EIS observed limited damage to the duct wrap in various locations with the duct wrap in fair condition. Recommendations: EIS recommends that the damaged areas of grey duct wrap in the basement be repaired as soon as possible. The ducts are only located approximately six feet above the basement floor and could inadvertently be damaged by building personnel working in the basement. The repair work should be performed by a licensed asbestos abatement contractor licensed to perform such work in California. The identified ACM in Casa Peralta should also be included in an asbestos Operations and Maintenance (O&M) program which is a set of guidelines and work practices designed to safely manage the building s ACM in-place until such time when all of the ACM is removed. 22

25 Fire Station No.13: EIS observed the following confirmed and suspect ACMs at Fire Station No. 13. Confirmed ACMs (Observed by EIS) - 12 x 12 brown floor tile/mastic, 700 sf, 20% C - Roofing Materials (shingles), 1,400 sf, 35% C - Roof flashing, Quantity unknown, 30% C - Fire Door, 20% C Suspect ACMs (Observed by EIS) - Exterior stucco siding - Suspect ACM The confirmed and suspect ACMs observed by EIS at Fire Station 13 are currently in good condition. Recommendations: It is recommended that the building s confirmed and suspect ACMs be included in an asbestos Operations and Maintenance (O&M) program for the property. An O&M program is a document with guidelines and work practices designed to safely manage the building s ACM inplace until such time when all are removed. 23

26 Fire Training Center: EIS observed the following confirmed ACMs at the Fire Training Center: Confirmed ACMs (Observed by EIS) - Sheetrock and joint compound, Composite result - <1% C, 910 sf, joint compound - 1-3% C, joint tape - 2-5% C - 9 x 9 Gold & brown floor tile, 96 sf, 10-20% C - Transite flue, 12 linear feet (lf), 10-15% Crocidolite (Cr) asbestos, 5-10% C - Penetration sealants on roof, 1-2 sf, 10-15% Cr The ACMs identified at the Fire Training Center all appeared to be maintained in fair to good condition. Recommendations: As there are ACMs present in this structure, it is recommended that the building s confirmed ACMs be included in an asbestos Operations and Maintenance (O&M) program which is a document with guidelines and practices designed to safely manage the building s ACM in-place until such time when all are removed. 24

27 Mulford Branch Library: EIS observed the following suspect ACMs at the Mulford Branch Library: Suspect ACMs (Observed by EIS) - Yellow sheet vinyl in restroom - Roofing materials - Floor tile/mastic beneath carpet - Sheetrock (drywall) and joint tape compound EIS observed the above-listed suspect ACMs at the Mulford Branch Library. EIS did not observe the ACMs identified in the 1992/1999 IHI asbestos documents. The previous IHI asbestos documents for the Mulford Branch Library were limited in nature and only sampled specific asbestos materials. The IHI report was not a full asbestos survey of the Mulford Branch Library building. Recommendations: EIS recommends an asbestos survey be conducted on the Mulford Branch Library in order to determine if ACMs are present or not. Once an asbestos survey has been performed, further decisions regarding the management of any ACMs can be made, if ACMs are identified. 25

28 Main Library: EIS observed the following suspect ACMs at the Main Library for San Leandro: Suspect ACMs (Observed by EIS) - Sheetrock and joint compound - 2 x 2 suspended ceiling tiles - 12 x 12 floor tiles - 2 x 4 suspended ceiling tiles The original main library building was constructed before According to Mr. Glen Contreras, City of San Leandro Maintenance Supervisor, the main library was rebuilt in the mid to late 1990s. Mr. Contreras stated that the original library structure was taken down to its structural framing and then the new library built around the original structure. The new library includes additional space and is larger than the original structure. The suspect ACMs EIS observed within the Main Library did not correspond with the ACMs identified in the previous asbestos inspection or abatement reports. Several of the documents provided to EIS were asbestos abatement reports that documented the removal of ACMs in the early to mid 1990s. This corresponds with EIS observations that none of the current building materials have been tested for asbestos content. It appears that most of the ACMs in the original library structure had been removed prior to the remodel of the main library building, but it is unknown if the replacement building materials contain asbestos or not. Without written documentation (either manufacturers documentation or laboratory testing results) stating that none of the replacement buildings do not contain asbestos, they are classified as suspect ACMs under current U.S. EPA and Cal/OSHA asbestos regulations. Recommendations: Because of the extensive renovations that occurred at the Main Library in the mid 1990s, EIS recommends a new asbestos survey be conducted on the San Leandro Main Library in order to determine if ACMs are present or not. Once an asbestos survey has been performed, further decisions regarding the management of any ACMs can be made, if they are present. 26

29 Police (Public Safety Bldg.): EIS observed the following suspect ACMs at the Public Safety Building: Suspect ACMs (Observed by EIS) - 2'x 4' suspended ceiling tiles - Sheetrock and joint compound walls - Vinyl sheet flooring - 12"x 12" grey vinyl floor tiles and mastic - Exterior stucco siding EIS did not observe any of the ACMs that were identified as being in the building in the 1992 ACM report. EIS did observe many suspect ACMs that were not listed in the 1992 IHI Asbestos Inspection. Reportedly, the Public Safety Building had been remodeled in the mid to late 1990s. From the information provided in the 1992 IHI Asbestos Inspection and the conditions as observed by EIS at the Public Safety Building in August 2008, it is unknown if ACMs are currently present in this building. Motor Barn - A single-story, wood-frame garage structure is located behind the Public Safety building that is used to garage police vehicles. This structure was built prior to 1960 and is approximately 1,200 square feet in size. There was no mention of this structure in the IHI asbestos inspection documents. Suspect ACMs observed by EIS included stucco on the exterior of the building. Recommendations: It is EIS opinion that most of the ACMs identified by IHI in 1992 were likely removed during the remodel in the mid to late 1990s. However, there were no asbestos abatement reports or other documentation for the Public Safety Building made available to EIS to confirm this. To identify if any ACMs are currently located in the Public Safety Building and the adjoining motor barn, EIS recommends an asbestos survey be conducted in order to determine if ACMs are present or not. Once an asbestos survey has been performed, further decisions regarding the management of any ACMs can be made, if they are present. 27

30 South Branch Library: EIS observed the following confirmed and suspect ACMs in the South Branch Library: Confirmed ACMs (Identified in Previous Reports) - Joint compound on west wall, 2% C - 12 x 12 beige floor tile/mastic, Tile: 15% C, Mastic: 10% C - HVAC vibration damper, 60% C Suspect ACMs (Observed by EIS) - 1'x 1' white acoustic ceiling tiles inside library (No sample results) ACMs were identified in the South Branch Library by IHI in 1993 as drywall joint compound, 12"x 12" beige floor tile & mastic, and in an HVAC vibration damper in the attic. One suspect ACM was observed by EIS was a 1' x 1' white ceiling tile that was not included in the previous IHI ACM survey report. The South Branch Library building is a converted house that is now used for the library. The original date of construction is pre There was carpet on the floor of the library covering the floor, therefore it is unknown if the beige floor tile identified by IHI in 1993 remains in the building. It was unclear if any renovations had occurred at the South Branch Library since the date of the IHI ACM Survey in Recommendations: EIS recommends an asbestos survey be conducted on the South Branch Library in order to determine if the previously confirmed ACMs are still present or not. Once an asbestos survey has been performed, then further decisions regarding the management of any ACMs can be made, if they are present. 28

31 South Offices: EIS observed the following suspect ACMs in the South Offices Suspect ACMs (Observed by EIS) - 2' x 4' suspended ceiling tiles - Sheetrock and joint compound walls - Tar and gravel roof covering materials - Penetration mastics on roof EIS observed the above listed suspect ACMs that were not listed in the IHI ACM survey reports from 1992/93. The South Offices appear to have been constructed between 1960 and EIS did not observe the ACMs identified in the IHI ACM survey/inspection report written in the early 1990s. Reportedly, the South Offices were remodeled in the mid to late 1990s. If the building was abated during a previous remodel/renovation, this would explain why none of the ACMs identified by IHI were observed in the building by EIS. It is EIS opinion that the building was most likely abated of the ACMs identified by IHI in their asbestos survey reports from the early 1990s. However, there were no asbestos abatement reports or other written documentation for the South Offices made available to EIS to confirm this. Recommendations: To identify if any ACMs are located in the South Offices, EIS recommends an asbestos survey be conducted in order to determine if ACMs are present or not. Once an asbestos survey has been performed, further decisions regarding the management of any ACMs can be made, if they are present. 29

32 General Recommendations In addition to the specific recommendations provided for each of the eight target properties provided previously, EIS makes the following general recommendations concerning the management of asbestos-containing materials by the City of San Leandro: Asbestos Awareness Training is required for city employees whose work activities may contact asbestos containing material (ACMs) or presumed asbestos containing material (PACM) but do not disturb the ACM or PACM during their work activities. This training consists of information regarding asbestos and its various uses and forms. Training also includes information on the health effects associated with asbestos exposure. The training will provide employees with a name and contact information of the person designated to carry out general responsibilities for ACMs located in City of San Leandro facilities and location of Operations and Maintenance (O&M) plan. (Asbestos Awareness training does not train employees to work with ACMs or to wear respiratory or personal protection equipment. Asbestos Awareness training provides employees with a basic understanding of the dangers of asbestos, asbestos regulations, and how to identify a potential asbestos exposure situation and whom to contact in such a situation). 30