HomeMy WebLinkAboutMagnolia Tree Park - 2274 Fig Tree Drive, Tustin (Asbestos Contamination & Screening Assessment) 11-11 & 13-23
Asbestos ■ Lead ■ Microbiology ■ Bacteria ■ Smoke & Soot ■ Industrial Hygiene ■ Laboratory ■ Project Management
2211 W. Orangewood Ave. ■ Orange, CA 92868 ■ Tel: 800.665.7586 ■ Fax: 714.937.0755
www.envirocheck.com
Limited Asbestos Fire Debris Screening
Assessment and Survey
Prepared for:
City of Tustin
300 Centennial Way
Tustin, CA 92780
Subject Property:
City of Tustin – Magnolia Tree Park
2274 Fig Tree Drive
Tustin CA 92780
Date(s) of Inspection: November 11 and 13, 2023
Report Date: December 12, 2023
Prepared by:
______________________________________
Michael Powers, CAC# 11-4750
2211 W. Orangewood Ave. ■ Orange, CA 92868 ■ Tel: 800.665.7586 ■ Fax: 714.937.0755
www.envirocheck.com
1.0 INTRODUCTION
This report presents the visual observations, analytical results and assessment for the Asbestos Fire
Debris Screening Assessment Survey performed on the subject property listed above by
Envirocheck, Inc. following the Tustin Hangar 1 Fire incident that occurred on November 7, 2023.
Please read entire report prior to initiating any action.
2.0 LIMITATIONS
The findings set forth in this report are strictly limited to the time, date and scope of the assessment
and the parameters set forth in the work authorization document approved or reviewed by the client
or the client’s representative. The results presented in this report are based on the visual assessment,
bulk PLM sampling and TEM Micro-Vacuum dust sampling performed by the Certified Site
Surveillance Technician (CSST) as directed by a Certified Asbestos Consultant (CAC) or by the
CAC directly. Visual assessment was limited to the locations listed and described below.
3.0 PROTOCOL AND TEST METHODS
• The exterior grounds of the subject property were visually inspected for the presence of suspect
Fire Debris, as potential Asbestos Containing Materials (ACM) and PACM Presumed Asbestos
Containing Materials (PACM). The exterior grounds and areas that were visually inspected were
limited to areas that were accessible and excludes enclosed spaces, e.g. sheds, storage containers,
etc.
• A visual survey and inspection for fire related debris of the exterior grounds was performed of
the subject property.
• Representative TEM Micro-Vacuum sampling was performed on interior surfaces of the subject
property.
• Asbestos visual survey and inspection was performed by Joshua Cornejo, CAC# 18-6156 of
Envirocheck, on November 11, 2023.
• Asbestos visual survey and inspection was performed by Larry Cornejo, CSST# 09-4480 of
Envirocheck, on November 11 and 13, 2023, under the direction of Joshua Cornejo, CAC# 18-
6156.
• Bulk (PLM) and Dust (TEM micro-vacuum) samples were submitted to Envirocheck’s in-house
laboratory, located at 2211 West Orangewood Avenue, Orange, CA 92868, (800) 665-7586.
• Envirocheck, Inc. NVLAP #200548-0
• The Inspector is Cal/OSHA certified and shall conform to procedures outlined in the EPA
Building Inspector Course.
2211 W. Orangewood Ave. ■ Orange, CA 92868 ■ Tel: 800.665.7586 ■ Fax: 714.937.0755
www.envirocheck.com
4.0 EXECUTIVE SUMMARY OF FINDINGS
• Samples were collected of the Debris (fire-related or other unidentifiable suspect materials) that
was observed and through PLM analysis was determined to be Asbestos Containing. (see
laboratory summary)
• The results from interior the TEM Micro-Vacuum sampling indicated levels exceeding
background levels. (see laboratory summary)
5.0 INVESTIGATION
At the time of the site inspection and assessment, Envirocheck, Inc. attempted to gather available
and pertinent information, including but not limited to history of the park, existing site conditions,
visual observations, and etc. to assist in this assessment.
General History –
• On November 7, 2023, Hangar 1 located at the former Marine Air Corp Air Base located at 2525
East Warner Avenue, Tustin, CA suffered a significant fire. During and shortly after the fire,
high winds in the area were prevalent and resulted in fire related debris and potential ACM to
blow and settle on exterior surfaces outside of the Base.
Site Conditions and Visual Observations –
• A visual inspection was conducted in the accessible exterior areas of the subject property. During
the visual inspection, visible suspect or fire-related debris was observed (approximately 82
square feet scattered). Relative interior surfaces in all inspected areas were in good condition and free
of visible debris.
2211 W. Orangewood Ave. ■ Orange, CA 92868 ■ Tel: 800.665.7586 ■ Fax: 714.937.0755
www.envirocheck.com
6.0 SUMMARY OF FINDINGS
6.1 Bulk PLM Sample Results
The sampled materials that exceeded the EPA definition of Asbestos Containing Material (ACM) of
>1% and/or the Cal-OSHA definition of Asbestos Containing Construction Material (ACCM) of
>0.1% and/or found as Trace for asbestos content were:
• Debris***
Table 6.1A Positive Results
# Location Material Notes %
Asbestos SqFt*
1 Park Exterior Debris*** N/A 12%
Chrysotile ~82
4 Park Exterior Debris*** N/A 13%
Chrysotile ~82
7 Park Exterior Debris*** N/A 10%
Chrysotile ~82
8 Park Exterior Debris*** N/A 12%
Chrysotile ~82
9 Park Exterior Debris*** N/A 16%
Chrysotile ~82
10 Park Exterior Debris*** N/A 8%
Chrysotile ~82
Table 6.1B Negative Results
# Location Material Notes
2 Park Exterior Debris*** N/A
3 Park Exterior Debris*** N/A
5 Park Exterior Debris*** N/A
6 Park Exterior Debris*** N/A
11 Park Exterior Debris*** N/A
12 Park Exterior Debris*** N/A
***Not covered by NVLAP accreditation.
2211 W. Orangewood Ave. ■ Orange, CA 92868 ■ Tel: 800.665.7586 ■ Fax: 714.937.0755
www.envirocheck.com
6.3 Dust Sample Results
Table 6.3 *TEM Dust Micro-vacuum Samples by ASTM D5755
# Sampling
Date
Sample Location/Item Concentration of
Asbestos Fibers
(Structures/cm2)
Result
1 11/13/2023 Women’s Restroom Entry Floor 51,761 Above
Background
2 11/13/2023 Women’s Restroom Baby
Changer
5,454 Above
Background
3 11/13/2023 Men’s Restroom Entry Floor <962.5 Below Background
* The benchmark used for this study to trigger further action is 5,000 structures per square
centimeter.
6.3.1 Interpreting Data – Asbestos in Settled Dust
“It is apparent that there is no single number that can be referenced to delineate when a surface is
‘clean.’ It appears that concentrations of asbestos dust less than 1,000 s/cm2 are unlikely to result
in elevated exposures. At the opposite extreme, values in excess of 100,000 s/cm2 should be cause
for concern. Values between these two extremes require the investigator to carefully consider the
possible exposure scenarios, including re-entrainment mechanisms and the exposed population.”
Ewing, Williams, Et al. “Observations of Settled Dust in Buildings.” Source: EIA Technical Journal,
Summer 1996, p. 17
“Based on the author’s experience, levels of asbestos in settled dust as determine by the microvac
technique are considered low if less than 1,000 s/cm2. Levels above 10,000 s/cm2 are generally
above background. Levels above 100,000 s/cm2 are considered high…” Source: Millette, James,
Hays, Steve. “Data: Levels of Asbestos in Dust” in Settled Asbestos Dust – Sampling and Analysis,
Lewis Publishers, CRC Press, 1994, p. 50:
“The benchmarks for asbestos in settled dust are not risk-based because there is no scientific
consensus on how to determine if these fibers will ever be inhaled. The dust benchmarks are based
on all structures equal to or greater than 0.5 µ; it was based on a weight of evidence approach that
considered 1) measured background values, 2) an experience standard developed by experts in the
asbestos identification field, and 3) benchmarks developed for other sites. The benchmark for
asbestos in accessible areas is 5,000 structures per square centimeter (s/cm2) and 50,000 s/cm2 for
infrequently accessed areas. The use of a benchmark for infrequently accessed areas is intended to
minimize the potential for recontamination of accessible areas.” Source: US EPA Lower Manhattan
Test and Clean Program, November 2008. This report summarized the results of the Lower
Manhattan Test and Clean Program, a voluntary program, offered to residents and building owners
concerned about potential residual contamination in buildings impacted by the collapse of the World
Trade Center (WTC) towers.
2211 W. Orangewood Ave. ■ Orange, CA 92868 ■ Tel: 800.665.7586 ■ Fax: 714.937.0755
www.envirocheck.com
7.0 DISCUSSION OF RESULTS AND CONCLUSIONS
From the information and data that was collected during the investigations, Envirocheck, Inc. provides the
following professional conclusions and opinions:
• Pursuant to the request of the City of Tustin, Envirocheck, Inc. has conducted an independent
investigation and site assessment for the presence of asbestos at the above subject school site in
response to the Tustin Hangar Fire. The assessment consisted of visual inspection of all
accessible exterior and outdoor grounds and areas for the presence of fire related debris, bulk
sampling and analysis for the presence of asbestos of any visible suspect fire related debris (if
found) and interior surface(s) TEM Dust sampling for settle asbestos fibers.
• Based on the data that was obtained from our assessment, Envirocheck, Inc. found visual
evidence of fire related debris and that the samples that were collected of the fire related visible
debris did contain asbestos.
• Based on the data that was obtained from our assessment, Envirocheck, Inc. found that the
interior surfaces TEM Dust samples did indicate asbestos fibers above the industry background
levels.
8.0 GENERAL RECOMMEDATIONS
• The results and findings from this assessment are limited to the date, time and scope of when it
was conducted. They are subject to change upon unforeseen conditions, including but not limited
to weather, additional investigations or testing that is conducted, etc. Conclusions offered herein
may be subject to additional advisement and/or supplemental requirements set forth by
governing agencies, including local, state and/or federal.
• When exterior asbestos containing fire related debris is present, the work to mitigate the debris shall be
performed in accordance with the EPA National Contingency Plan (NCP) that was enacted on November
21, 2023 and with the Pre-Approved Procedure 5 Work Plan in accordance with South Coast Air Quality
Management District (SCAQMD) Rule 1403 that was enacted on November 22, 2023 both of which were
submitted to and on file with the City of Tustin.
• When asbestos fibers in the settle dust in interior surfaces are found via TEM Micro-Vacuum
sampling, a proper asbestos abatement and clean-up Work Plan should be prepared for the
decontamination of the affected areas and/or contents.
• All work involving the removal and/or disturbance of asbestos containing materials and/or the
decontamination of asbestos contaminated areas and/or contents shall be performed by a DOSH
licensed contractor under appropriate abatement procedures
2211 W. Orangewood Ave. ■ Orange, CA 92868 ■ Tel: 800.665.7586 ■ Fax: 714.937.0755
www.envirocheck.com
9.0 STATEMENT OF QUALIFICATIONS
LABORATORY ACCREDITATION
Envirocheck, Inc. is a fully accredited and certified laboratory, maintaining proper State and Federal licenses, permits
and certifications. Our employees receive through training in project management, supervision, inspection and asbestos
abatement training. Continuing education is maintained through programs designated to renew certification and to work
with special supervisory and management needs.
Corporate accreditation and credentials are earned by proven proficiency through a number of independent audits and
investigation. Since their inception, Envirocheck, Inc. has consistently been awarded all credentials and accreditations
sought.
NIST/NVLAP
Nation Institute of Standards and Technology
National Voluntary Laboratory Accreditation Program
Lab # 200548-0
Accuracy of Polarized Light Microscopy (bulk) analysis is evaluated by participation in NIST’s National Voluntary
Laboratory Accreditation Program (NVLAP). AHERA requires NVLAP accreditation for bulk asbestos analysis (by
PLM) performed during school building surveys.
NIST, formerly NBS-National Bureau of Standards, primarily focuses on development and establishment of quality
control standards for laboratories. NIST ensures that standards are met through a thorough accreditation process.
Accreditation for laboratories performing analysis of bulk materials for the presence of asbestos is awarded after the
laboratory successfully passes an on-site inspection, during which the facility, technicians, processes and record-keeping
are carefully evaluated. Additionally, each quarter, the laboratory must successfully analyze audit bulk material samples
for the presence, type and percentage of asbestos.
QUALITY ASSURANCE
Envirocheck, Inc. thoroughly monitors quality control through a detailed program evaluating and documenting the
ability to consistently reproduce analytical results. To accomplish this, we have developed a standard set of protocols
that encompass sample collection, handling, analysis, and reporting. Data quality is evaluated based on both inter -
laboratory control and duplicate analysis.
All PLM (Polarized Light Microscopy) and PCM (Phase Contrast Microscopy) samples taken or received by
Envirocheck, Inc. undergo proper chain -of-custody and log-in documentation. Contamination of bulk samples is
controlled by ensuring that only qualified personnel collect the samples in an approved container and that PCM is
determined by blind replicate analysis on 10% of all randomly selected samples by an Envirocheck, Inc. Quality Control
Manager and each microscopist. Each microscopist is issued one reference slide per day for analysis. Additionally,
quality control is maintained by:
Polarized Light Microscopy (PLM): On a quarterly basis, we exchange round robin samples with two other laboratories
in our area. Our sample results are compared with the results of the other laboratories for asbestos presence, type and
percentage composition. Duplicate and referenced samples are issued on a daily basis by the Quality Control Manager
and also are analyzed for asbestos presence, type and percentage. The data for these quality control activities is then
compiled and control charts are produced to help interpret the sample results with regard to inter/intra analyst precision
and accuracy, as well as inter/intra laboratory precision and accuracy.
Phase Contrast Microscopy (PCM): Each analyst’s Coefficient of Variation (CV) is determined by daily analysis of
reference slides. The established CV for the analyst is then used to verify that 10% blind recount of all samples is within
acceptable limits. Regular updates if intra/inter analysis and intra/inter laboratory control charts are produced form the
data collected. Round robin sample exchange is performed from PCM samples, as was described for PLM.
2211 W. Orangewood Ave. ■ Orange, CA 92868 ■ Tel: 800.665.7586 ■ Fax: 714.937.0755
www.envirocheck.com
10.0 ASBESTOS RELATED TERMS
AHERA – Asbestos Hazard Emergency Response Act (Regulates School Facilities)
ASHARA – Asbestos School Hazard Reauthorization Act. (includes public and commercial buildings under AHERA
regulation)
ACM – Asbestos Containing Materials (materials containing greater than one (1) percent by weight)
ACCM – Asbestos Containing Construction Materials (CAL-OSHA’s term for materials containing greater than one
tenth of one (0.1) percent by weight)
PACM – Presumed Asbestos Containing Materials (materials considered asbestos containing without laboratory
analysis)
CAC – Certified Asbestos Consultant (State of California certified individual allowed to perform all aspects of asbestos
related inspection, management, planning, and design work and to direct CSST(s) and review and execute asbestos
reports under state law.)
CSST – Certified Site Surveillance Technician (Allowed to perform all aspects of asbestos related inspection,
management, work under the direction of a CAC.)
CAL- OSHA a.k.a. (DOSH) Division of Occupational Safety and Health (California Governing body regulating worker
protection)
OSHA – Occupational Health and Safety Administration
NIOSH – National Institute of Occupational Safety and Health
EPA – Environmental Protection Agency (Regulates Environment and Waste Stream)
DOT – Department of Transportation
NESHAPS – National Emissions Standard for Hazardous Air Pollutants
SCAQMD – South Coast Air Quality Management District (local division of NESHAPS)
NVLAP – National Voluntary Laboratory Accreditation Program
AIHA – American Industrial Hygiene Association
CFR – Code of Federal Regulations
CCR –California Code of Regulations
PLM – Polarized Light Microscopy (also known as “Bulk” sample)
PCM – Phase Contrast Microscopy
TEM – Transmission Electron Microscopy
Laboratory Report Terms:
ND- None Detected
A – Area Sample (air monitoring)
AA - Area After (Clearance Type Sample)
P – Personal Sample (Employee monitoring type sample)
EX – Excursion (Employee monitoring type of sample during peek activities)
BK- Blank (used for quality assurance)
2211 W. Orangewood Ave. ■ Orange, CA 92868 ■ Tel: 800.665.7586 ■ Fax: 714.937.0755
www.envirocheck.com
11.0 CERTIFIED ASBESTOS CONSULTANT SIGNATURE
Any individual performing services as an asbestos consultant or site surveillance technician as referenced and
defined in section 1529(b) of Title 8 of the California Code of Regulations must be certified by the State of
California, Division of Occupational Safety and Health (DOSH). Asbestos consultant shall maintain copies
of AHERA training certificates for management planner, abatement project designer, abatement contractor
and supervisor, and all subsequent annual refresher courses. The complete abatement project designer course
certificate is only required for certifications provided after July 1, 1994. Site surveillance technician
applicants shall maintain copies of AHERA training completion certificates for inspector, and abatement
contractor and supervisor, and all subsequent annual refresher courses. Certificates for abatement worker and
abatement project designer may be utilized in lieu of the abatement contractor and supervisor certificate.
Specific qualifications are required pursuant to section 1529(o) of Title 8 of the California Code of
Regulations for certification. The educational qualifications, (diploma, official transcript, or other proof), and
qualifying work experience as specified in Business and Professions Code sections 7184 and 7185 have been
met by the individual(s) performing asbestos related consulting activities or site surveillance technician
activities. Qualifying work experience includes technical work associated with asbestos consulting activities.
Written references attesting to the applicant's qualifying work experience which are certified under the
penalty of perjury as required.
______________________________________
Michael Powers, CAC# 11-4750
2211 W. Orangewood Ave. ■ Orange, CA 92868 ■ Tel: 800.665.7586 ■ Fax: 714.937.0755
www.envirocheck.com
APPENDIX A: Floor Plan Sketch
2211 W. Orangewood Ave. ■ Orange, CA 92868 ■ Tel: 800.665.7586 ■ Fax: 714.937.0755
www.envirocheck.com
2211 W. Orangewood Ave. ■ Orange, CA 92868 ■ Tel: 800.665.7586 ■ Fax: 714.937.0755
www.envirocheck.com
APPENDIX B: Laboratory Results and Chain of Custody
2211 W. Orangewood Ave. ■ Orange, CA 92868 ■ Tel: 800.665.7586 ■ Fax: 714.937.0755
www.envirocheck.com
2211 W. Orangewood Ave. ■ Orange, CA 92868 ■ Tel: 800.665.7586 ■ Fax: 714.937.0755
www.envirocheck.com
2211 W. Orangewood Ave. ■ Orange, CA 92868 ■ Tel: 800.665.7586 ■ Fax: 714.937.0755
www.envirocheck.com
2211 W. Orangewood Ave. ■ Orange, CA 92868 ■ Tel: 800.665.7586 ■ Fax: 714.937.0755
www.envirocheck.com
2211 W. Orangewood Ave. ■ Orange, CA 92868 ■ Tel: 800.665.7586 ■ Fax: 714.937.0755
www.envirocheck.com
2211 W. Orangewood Ave. ■ Orange, CA 92868 ■ Tel: 800.665.7586 ■ Fax: 714.937.0755
www.envirocheck.com
2211 W. Orangewood Ave. ■ Orange, CA 92868 ■ Tel: 800.665.7586 ■ Fax: 714.937.0755
www.envirocheck.com