The URL can be used to link to this page

Home My WebLink AboutCC AG PKT 2004-11-08 #K AGENDA REPORT DATE: November 8, 2004 TO: Honorable Mayor and City Council THRU: John B. Bahorski, City Manager FROM: Mark K. Vukojevic, P.E., Director of Public Works /City Engineer SUBJECT: . ZOETER SCHOOL - DAYCARE SITE UPDATE SUMMARY OF REQUEST: Receive and file the attached report and provide direction. BACKGROUND: On September 27, 2004, Staff presented City Council information indicating the presence of Lead Based Paints (LBP) and Asbestos Containing Materials (ACM) within the Zoeter School site. The site, which is owned by the Los Alamitos Unified School District, is leased to the City of Seal Beach and then sublet to two day care operators, Under the Rainbow and Sun N Fun. City Council recommended that the site be closed until further examinations and conclusions could be determined. The day care operators were notified that evening and the site was closed the following day. Since the September 27th notice, the City conducted further testing in the buildings occupied by Under the Rainbow and Sun N Fun. That testing confirmed the presence of . ACM and LBP in the buildings occupied by both operators. A copy of the second report is enclosed under Attachment A. However, amounts found within the Sun N Fun operation were determined to be quickly mitigated. A brief presentation was given to City Council on October 11, 2004 and City Council directed Staff to work with the Sun N Fun operators to obtain re- certification for re- occupation. The scope of work for Under the Rainbow was considered to be large and was requested to be discussed at a future City Council meeting. Council agreed to the following guiding principals for the future planning of the site: Community need, costs, funding, legal responsibilities and a review of the advantages and disadvantages. Staff, and the City's environmental consultant coordinated an effort to assist Sun N Fun in their clean -up efforts at the preschool. Parents completed touch up painting of the building interior and placed new floor tiles. Sun N Fun hired a contractor to vacuum any lead dust inside and outside of the building. The contractor also scraped,-removed, and sealed loose and flaky paint around the exterior of the building. The City's environmental consultant observed the work and performed additional testing which Agenda Item k cleared the site for occupation. The work was completed on Friday, October 22, 2004 and Sun N Fun was back in the building on Monday, October 25, 2004. The Public Works Department consulted with a specialized environmental and health care consultant, Meredith and Associates to review the information of both reports. Meredith used the assessment data as input for two lead risk assessment models that are designed to predict blood lead levels in children that could result from exposure to lead in dust, paint, or soil. Both models were originally developed for use in residential Settings. To better reflect the conditions at the site,, and consider the effects of exposure to the school, the models were modified. The modified models predicted blood lead levels below the Centers for Disease Control and Prevention (CDCP) threshold. These preliminary evaluations notwithstanding, the EPA's nationwide Lead Awareness Program states that the only conclusive way to determine if a person has been adversely affected is with a blood lead test. In response to this information, the Public Works Department sent a letter to the operator and to all available parents regarding this information. A copy of this letter is enclosed under Attachment B. Several residents have contacted the City for additional information and the City has provided this as it has become available. The future of the Zoeter School site might best be served by a special ad -hoc committee as noted in a separate staff report for a Streets, Storm Drain, and Facilities Committee. As outlined in Attachment C, several options exist at the site including abatement and rehabilitation of the existing building, demolition, construction of new buildings of various sizes, modular buildings, conversion to open space, and construction of a community center and /or gymnasium. Staff has identified known costs of approximately 5765,000 to pay off the capital lease, 5250,000 to 5350,000 in abatement costs, and approximately $1,800,000 in needed facility repairs /improvements. Staff is recommending that the future planning of the site be referred to the proposed Streets, Storm Drain, and Facilities Committee for discussion on funding propositions and is requesting direction from the City Council. FISCAL IMPACT: Unknown at this time • RECOMMENDATION: Receive and file the attached report and provide direction. • Agenda Item_ Prepared By: � J Mar K. Vukojevic, P.E. Director of Public Works /City Engineer N• . PND APP 'r. ED: .r 1 i Jo, 1:.: ahorski C Manager Attachments: A. Asbestos, Lead and Mold Baseline Sampling Report . B. October 26, 2004 Letter to Under the Rainbow C. Preliminary Alternatives for the Zoeter School Property. Agenda Item • • i c,fy Department of Memo Public Works To: City Council - Oil From: Mark Vukojevic, P.E., Director of Public Works /City Engineer 1" CC: John Bahorski, City Manager • Date: November 3, 2004 Re: Zoeter School — Daycare Site Update Agenda Item K Please add the following attachments to the Zoeter School Daycare Site Update Agenda Report Item K for the November 8, 2004 Council Meeting. Attachment A: Asbestos, Lead and Mold Baseline Sampling Attachment B: October 26, 2004 Letter to Under the Rainbow Attachment C: Preliminary Alternatives for the Zoeter School Property Attachment A: Asbestos, Lead and Mold Baseline Sampling Report Agenda !team ✓ PACIFIC 0 ENVIRONMENTAL b ASBESTOS, LEAD AND MOLD BASELINE SAMPLING REPORT ZOETER SCHOOL • 357 12TH STREET SEAL BEACH, CALIFORNIA 90740 November 4, 2004 Pacific Environmental Project Number 04193 30101 Town Center Dr. / Suite 107 I ;a =a. 363 7200 Laguna Niguel. California 91677 ra`x t ' 94-; 3637110 www.pacifitcnviror.men : aLcom I PACIFIC o ENVIRONMENTAL • e ASBESTOS, LEAD AND MOLD BASELINE SAMPLING REPORT ZOETER SCHOOL • 357 STREET SEAL BEACH, CALIFORNIA 90740 • Prepared for: Joe Stango TEC Engineering 524 Via De La Valle, Suite 308 • . Solana Beach, California 92075 • • Prepared by: Pacific Environmental Company • 30101 Town Center Drive, Suite 107 . Laguna Niguel, California 92677 • November 4, 2004 • - Pacific Environmental Project Number 04193 • • 30101 Town Center Dr. ! Suite 107 41:a! - 363 7200 i a'w 949 7110 wpacificenvironmental.com • Laguna Niguel, California 92677 ' - "'S �..' 363 7170 • • TABLE OF CONTENTS ASBESTOS, LEAD AND MOLD BASELINE SAMPLING REPORT ZOETER SCHOOL 357 STREET SEAL BEACH, CALIFORNIA 90740 INTRODUCTION BACKGROUND INFORMATION 1 ASBESTOS AIR SAMPLING 3 LEAD DUST SAMPLING 4 LIMITED MOLD INSPECTION g' . SUMMARY 9 LIMITATIONS 11 Appendix A - Site Photographs - • • Appendix B Site Sample Plans e I• ^^a' r 6Mnir1 Crimplin n 1 rls_ • ASBESTOS, LEAD AND MOLD BASELINE SAMPLING REPORT ZOETERSCHOOL 357 12TH STREET . SEAL BEACH, CALIFORNIA 90740 INTRODUCTION • Pacific Environmental Company (PEC) was previously retained by The Environmental Company to perform an asbestos and lead -based paint survey at the Zoeter School Buildings in Seal Beach, California. The results of our survey, as presented in our report dated September 27, 2004, indicate that asbestos- - containing materials (ACM) and lead -based paints (LBP) were used in the construction of the buildings at the Site. Due to the damaged condition of some of the ACM and the defective condition of the LBP, we were retained to conduct baseline sampling to evaluate the potential for exposure to airborne asbestos fibers and lead- contaminated dust. In order to evaluate the potential for exposure to airborne asbestos fibers, PEC collected ambient air samples and had them analyzed by transmission electron microscopy (TEM) in accordance with the Asbestos Hazard Emergency Response Act (AHERA) Protocol by an independent NVLAP laboratory. TEM analysis has the capability of discriminating asbestos fibers and is generally considered the industry • standard for identifying and characterizing asbestos fibers. Samples were collected from ten representative locations throughout the property. In order to evaluate the potential for exposure to lead dust, PEC collected dust wipe samples from each room, the corridors, miscellaneous toys and tabletops and play area soils. This sampling strategy was intended to identify the potential for exposure associated with the defective LBP. During the initial assessment, it was determined that portions of the building had sustained water damage over the years. As such, we conducted limited microbial sampling to evaluate the potential presence of mold contamination. BACKGROUND INFORMATION • The subject site consists of two single -story school buildings, which were constructed in -the late 1940's. The buildings are connected by a common breezeway. The buildings are wood framed structures With a stucco finish, built over a concrete slab on grade. Interior floorings include sheet vinyl, asbestos floor tiles, carpet and exposed concrete. Walls are drywall or plaster and the ceilings are finished with an acoustic texture. The property was recently occupied with daycare /preschool facilities which were temporarily closed pending the results of further hazard analysis. There are currently two operators of child -care facilities at the subject site. The majority of the property (Building A) is operated by the City of Seal Beach's Under the Rainbow Program. Sun -N -Fun operates another independent daycare facility in one room of Building B. The corner room that is occupied by 'Sun N Fun' is in considerably better condition than the other portions of the school. The paint is in fair condition and we did not observe as many paint chips on the ground. compared to other • areas Based on the results of our initial survey the following materials are classified as asbestos - containing materials (ACM) or asbestos - containing construction materials (ACCM). • Pacific Environmental Company 1 - Building Building Material Location Est. Qty. 9" Vinyl Floor Tile Corridor, Rooms 2 and 5 (partially 3,300 SF concealed under carpet -see plan) Acoustic Ceiling Throughout 7,900 SF Building A Air Cell Duct Wrap Duct Registers 80 SF Exterior Stucco Exterior Walls _ 4,500 SF Roof Penetration Mastic Roof Penetrations 200 SF Portions of Corridor, Rooms 8,9,10 and 11 9" Vinyl Floor Tile (partially concealed under carpet) and 6,100 SF Kindergarten (assumed) Acoustic Ceiling Corridors, Rooms 8, 9, 10, 11 and 8.000 SF Building B Kindergarten (assumed) - • Air Cell Duct Wrap Duct Registers 80 SF Exterior Stucco Exterior Walls 4,800 SF Roof Penetration Mastic Roof Penetrations 200 SF LBP components that have been identified are summarized in the following table: • •Location _ Lead - Positive Components Ceramic Tile Around Drinking Fountains Eaves & Fascia Metal Support Poles and Poles /Railings on Breezeway, Downspouts, Gutters Exteriors Wood Doors, Door Fames, Window Frames, Window Sills, and Window Sashes Wood Lattice Wall on Breezeway - Wood Siding Around Doors • Location Lead - Positive Components • Wood Doors & Door Frames Window Sills, Window Sashes, and Window Frames. • - . Cabinet in Office Corridor (Side C) • Building A Corkboard in Rooms 2 & 31 Corkboard Trim in Rooms 3, 4, & 6, Wood Ceiling Light Frames, Skylights Water Fountain Tile, Ceramic Sink and Wall Tile, Toilet Partitions • Painted Wood Walls • Wood Doors & Door Frames, Door Jambs and Baseboards - Window Sills, Window Sashes, and Window Frames, and Skylight Frames Corkboard Trim in Room 11 Building B Wood Cabinet Frames - Ceramic Baseboard Tile, Toilet Partitions Room 8 "B" Side, Staff, Boys and Girls Restroom Walls and Ceilings Pacific Environmental Company 2 • ASBESTOS AIR SAMPLING To evaluate the potential presence of airborne asbestos fibers, air sampling was conducted from representative locations throughout the school. Air sampling is indicative of the conditions present at the time of sampling and conditions can change with activity or occupancy, For example, during typical day -to- day childcare operations, active children and their caretakers occupy the buildings and windows and doors will be periodically opened and closed. Occasional housekeeping activities such as vacuuming and dusting also would be performed from time to time, and these activities could result in increased air movement through the buildings and the re- suspension of dust. Air samples were collected using Gast® high flow air sampling pumps. The pump flow rates were checked • before and after each use with a calibrated rotameter. The air sampling was performed by Thomas Gannon, a CaIOSHA Certified Site Surveillance Technician on September 29, 2004 under the direction of Michael Lyssy, a CaIOSHA Certified Asbestos Consultant. In order to obtain air samples, measured volumes of air are drawn through a 25mm diameter air monitoring cassette containing mixed cellulose ester filter membranes with a pore size less than 0.45 which were submitted under chain of custody to our independent NVLAP certified laboratory. The air samples were analyzed by the method described in "Methodology for the Measurement of Airborne Asbestos by Electron Microscopy," U.S.,EPA, 1984, and to conform with the analytical method described in 40 CFR Part 763, "Asbestos- Containing Materials in Schools," October 30, 1987, final rule under AHERA. One field blank and one laboratory blank sample were analyzed for quality control purposes. EPA/AHERA standards dictate that when less than 70 structures per square millimeter is found on the filters inside the abatement area, an asbestos response action is considered complete (40 CFR, Part 763, October , 30, 1987). Based on this, we have utilized the clearance criteria to establish a threshold for determining the presence of airborne contamination. The results of the air samples collected are located in the appendices of this report and are detailed in the following table: Sample Detail - Structure ID Date Sample Location /Description Time On /Off Avg. Total Volume Concentration LPM Time '0929-01 9/29/04 Kindergarten Room, Northeast Comer 0838 1042 10.0 124 1240 <0.0052 0929 -02 9/29/04 Room 11, Southeast Area 0839 1044 10.0 125 1250 <0.0051 • 0929 -03 9/29/04 Room 9, Northwest Area 0842 1047 10.0 125 1250 <0.0051 0929 -04 9/29/04 Room 10, Southeast Area • 0840 1046 10.0 126 1260 <0.0051 0929 -05 9/29/04 Room 8, Northwest Area 0845 1049 10.0 124 1240 <0.0052 0929 -06 9/29/04 Room 4, North Area 1110 1313 10.0 123 1230 <0.0052 0929 -07 9/29/04 Room 1, Northeast Area 1113 1316 10.0 123 . 1230 <0.0052 0929 -08 9/29/04 Room 2, Southeast Area 1115 1319 10.0 124 1240 <0.0052 0929 -09 • 9/29/04 Room 3, Center Area 1118 1323 10.0 125 1250 <0.0051 0929 -10 9/29/04 Room 7, Northwest Area 1121 1326 10.0 125 1250 <0.0051 0929 -11 9/29/04 Feld Blank 0 0 0 0 0 0 0929 -12 9/29/04 Laboratory Blank 0 0 I• 0 0 0 0 Pacific Environmental Company 3 • • • • The results of the air samples collected indicate that at the time of sampling, there were no asbestos structures detected in the ambient atmosphere inside of the building: While this indicates a low potential for exposure at the time of sampling, it should be noted that the conditions can change with activity or occupancy. In order to prevent the possibility of future exposure, the damaged ACMs need to be removed by an asbestos abatement contractor. Aggressive sampling methods (i.e. aggravating horizontal surfaces and the air with fans and blowers during the sampling) were not utilized for our assessment due to the fact that we were trying to determine ambient exposure levels which would be indicative of current conditions. LEAD DUST SAMPLING Baseline dust wipe and soil sampling was conducted at the subject site by Sean Tillema, a DHS Certified Lead Paint Inspector /Assessor, on September 30, 2004. The samples were submitted to an independent laboratory for analysis. We have drawn on a combination of HUD (Technical Guidelines for the Evaluation and Control of Lead -Based Paint Hazards in Housing, 1995), EPA (40 CFR 745, 2001) and CADHS (Title 17, CCR, Division 1, Chapter 8) standards in order to define bur determination of contamination The referenced Guidelines specify the following levels for clearance: • Dust: Floors 40 µg /ft Window Sills 250 Rg /ft Window Wells 400 p.g /ft Soil: 400 mg /kg for high contact play areas: requires interim control 1000 mg /kg for low- contact areas: requires interim control • 5000 mg /kg interim control not appropriate The results of the sample analysis are presented in the following tables: Dust Wipe Sample Results Sample No. Sample Location Area (ft2) Lead (µg /ft 001 Building A Interior — Corridor Floor, Near Entry 0.50 , <30 002 Building A Interior— Office Floor, Near Door to Exterior 0.50 <30 003 Building A Interior — Room 9 Floor, Entry Door to Exterior 0.50 90 004 Building A Interior — Room 8 Floor, Entry Door to Exterior 0.50 40 005 Building A Interior— Room 10 Floor, Entry Door to Exterior 0.50 250 006 Building A Interior— Room 11 Floor, Below Window 0.50 100 007 Building A Interior — Restroom Floor, Near Breezeway ' 0.50 <30 008 Building A Interior — Restroom Floor • 0.50 <30 009 Building A Interior— Room 15 Floor, Below Window 0.50 70 010 Building A Interior — Lounge Floor, Storage Area 0.50 <30 011 I Building A Interior— Corridor Floor, Exit to Breezeway 0.50 210 Pacific Environmental Company 4 • Sample No. - - Sample Location Area (ft2) Lead (µglft I 012 Building B Interior - Room 17 Floor, Entry Door to Exterior 0.50 1,500 i 013 Building B Interior - Room 18 Floor, Below Window 0.50 40 014 Building B Interior- Room 19 Floor, Below Door 0.50 740 015 Building B Interior- Entry Door Floor, Sun N' Fun 0.50 <30 016 Building B Interior Corridor Floor, Exit to Breezeway 0.50 130 017 Building B Interior- Corridor Floor, Exit to Restrooms 0.50 <30 018 Building B Interior- Room 20 Floor, Entry Door to Exterior 0.50 50 019 Building A Interior - Room 8 Window Sill 1.68 92 020 Building A Interior - Room 9 Window Sill 1.68 30 021 Building A Interior- Room 10 Window Sit 1.68 20 022 Building A Interior - Room 15 Window Sill 1.60 1,300 023 Building A Interior- Lounge Window Sill 1.60 180 024 Building A Interior- Office Window Sill 1.60 420 025 Building A Interior = Restroom (Nearest Breezeway) Window Sill 1.83 55 026 Building A Interior - Restroom Window Sill 1.83 ' - 130 027 Building B Interior - Room 20 Window Sill 1 1.76 1,200 028 Building B Interior - Room 19 Window Sill 1.76 i 53 029 Building B Interior- Room 18 Window Sill 1.76 120 030 Building B Interior - Room 17 Window Sill 1.76 2,400 031 Building B Interior - Sun N' Fun Upper Window, Window Sill 1.76 81 032 .Buildinq B Interior- Sun N' Fun Lower Window, Window Sit 1.76 25 . . 033 Building NB Exterior - Breezeway Floor, Entry to "A" 0.50 1,900 034 Buildinq NB Exterior - Breezeway Floor, Entry to "B" , 0.50 710 035 Building A Exterior - Floor (d Entry to School, Parking Lot Side 0.50 <30 036 Building B Exterior - Entry Floor (o? Entry to Sun N' Fun 0.50 80 037 Building A Exterior - Entry Floor to Room 15 0.50 350 . 038 Buildinq A Exterior - Window Sill, Room 15 0.87 1,400 039 Buildinq B Exterior - Window Sill, Room 18 0.83 90 040 Building B Exterior - Entry Floor, Room 0.50 - 170 041 Buildinq B Exterior- Entry Floor, Room 19 0.50 420 042 Building B Exterior - Window Sill, R00m 19 0.77 1,200 043 Buildinq A Exterior - Window Sill, Room 8 0.94 5,700 044 Buildinq A Exterior - Entry Floor, Room 8 0.50 660 045 Building A Exterior - Window Sill, Room 9 0.94 2,000 046 Buildinq A Exterior - Entry Floor, Room 9 0.50 13,000 047 Building A Exterior - Window Sill, Room 10 0.94 2,300 • 048 Building A Exterior - Entry Floor, Room 10 0.50 21,000 . 049 Building A Exterior - Window Sill, Room 11 0.94 1,700 050 Building A Exterior - Entry Floor, Room 11 0.50 1.900 051 Building B Exterior - Window Sill, Sun N' Fun _ 1.02 _ 120 Pacific Environmental Company 5 • • The majority of the dust samples from the Under - The - Rainbow and vacant portions of the property exceed the levels specified for clearance, which is indicative of lead dust contamination at the property. The samples from the Sun -N -Fun areas were below clearance criteria. LEAD IN SOIL SAMPLING In order to evaluate the potential for lead contamination in the exposed soils at the property as a result of the identified defective exterior paints, a composite sample was collected and analyzed for lead content. There are very limited quantities of exposed soil at the she and composite sample collection methods were utilized. The results of the sample are presented in the following table: Soil Sample Results Sample No. Sample Location Results (mg /kg) i 001S Bare Soil Area - Composite Sample 250 The results of the composite soil sample indicate that the defective paints have not likely contaminate the surficial soils at the property. • Composite sampling is allowed under USEPA guidance for assessing lead at residential properties, data averaging can modify outliers and "hot- spots," and reliance on a single composite sample can considered. The DTSC spreadsheet lead risk model LEADSPREAD (Version 7, 1999) suggest that lead in soil at this concentration would not produce blood levels above 10 ug /dL in a residential child receptor (i.e., at the 99% confidence limit and assuming no ingestion of site -grown vegetables). The composite soil sample concentration also lies below the IIUD clearance threshold for high- contact play areas (i.e., sandboxes, etc.) of 400 mg /kg. QUALITATIVE DUST WIPES FROM TOYS Due to the existence of defective LBP in close proximity to children's play areas, several of the play toys and tabletops were also tested for the presence of lead dust. Analysis of the samples from these areas is strictly qualitative due to the inconsistency and irregularity of their shapes which makes it difficult to ascertain the area of the surface. Qualitative Dust Wipe Sample Results from Irregular S_ urfaces Sample No. I Sample Location Area ft2 Lead (µg) A Building A Interior — Room 8, Child's Slide N/A <20 B Building A Interior— Room 9, Child's Table N/A <20 • Pacific Environmental Company 6 • • Sample No. Sample Location Area (ft?) Lead (µg) C Building A Interior— Room 10, Child's Table N/A <20 D Building A Interior — Room 11, Child's Slide N/A <20 E Building A Interior — Room 15, Child's Bookshelf N/A <20 F Building A Exterior — Room 8, Child's Chair N/A 450 G Building A Exterior — Room 8, Child's Car N/A 30 • H Building A Exterior — Room 9, Child's Table N/A 280 Building A Exterior — Room 10, Child's Picnic Table N/A 140 Building A Exterior— Room 11, Child's Storage Box Top I N/A 8,800 K Building B Exterior — Sun N' Fun, Child's Toy N/A 60 L Building B Exterior — Room 18, Lunch Table N/A 30 The results of the analysis indicate that several of the toys and furniture items are contaminated with lead dust. The results reflect the total lead detected on each sample. Since the sample areas were not calculated, we are considering any lead dust present as contamination. LIMITED MOLD INSPECTION Pacific Environmental Company has conducted mold sampling to address potential indoor air quality concerns at property as well. Microbial sampling and assessment methods were based in part on the protocols outlined in Bioaerosols: Assessment and Control, ACGIH. Since no exposure guidelines have been established by any governmental agency, the term "contamination" is used to indicate the presence of mold or fungus at levels higher and /or qualitatively different from ambient outdoor air. The term is also used to indicate visible fungal growth on surfaces and in wall cavities. Mold, also know as fungi, are a group of microscopic organisms that can be found virtually everywhere; indoors and outdoors. In the presence of continuous or excessive moisture, mold can reproduce rapidly to produce potentially adverse environmental conditions. It is our goal to determine if these conditions exist inside of the school struture at the time and date of our investigation. It is generally accepted in the scientific and medical communities that molds can be allergenic, infectious, and sometimes produce mycotoxins. There are no uniformly accepted numerical guidelines for the interpretation of microbial contamination. This absence of standardization makes it somewhat difficult to establish comprehensive conclusions about whether or not adverse conditions do exist. The conclusions drawn in this report are intended to provide some basic interpretative information using certain assumptions and facts that have been extracted from a number of authoritative bodies and peer reviewed text. In the absence of set • standards, the user of this information must determine the applicability of this report to each unique situation. Identification of the presence of a particular mold in an indoor environment does not necessarily mean the occupants are or are not being exposed to unhealthy conditions. The scope of this assessment included a comprehensive visual inspection, moisture analysis of accessible building materials, collection of necessary samples, and interpretation of data. Our conclusions are based solely upon our visual observations and collection of limited data from the inspection site and should not be considered comprehensive. Waterproofing forensics is beyond the scope of this investigation. Pacific Environmental Company 7 • • • • All accessible areas were visually evaluated for potential mold growth. There were visible indications of, historic water damage at the property which appear to be a result of a failing roofing system. A hand held thermometer /hygrometer was placed in selected areas throughout the property to record measurements for short periods of time. Measurement and recording of air temperature and relative humidity is used to determine the presence of a current moisture problem. A Protimeter moisture meter was applied to building materials (walls, cabinetry, etc.) throughout the structure. The determination of moisture content is performed to detect building materials containing greater than 15% moisture. Fungi that feed on building material such as drywall or lignin of the wood must have each of three requirements for growth: moisture (moisture content greater than approximately 18 -20 %), air, and favorable temperature. All of these items are required for microbial amplification to.occur. The American Society of Heating, Refrigeration and • Air Conditioning Engineers (ASHRAE) provides guidance suggesting that habitable spaces maintain a relative humidity between 30% and 60% to minimize the growth of most types of mold. • Moisture levels of the accessible building materials at the time of our inspection throughout the subject site were all below 15 %, which is within acceptable levels at the time of our inspection. Temperature readings ranged from 65 to 80 degrees and relative humidity readings ranged from 53 to 70 percent, which would be considered typical for a building that has been vacant for several days. Air sampling generally indicates the different types of bioaerosols, primarily mold spores, that are present in the ambient_air_in -a_ referenced area. : Air sampling is also_used to reveal information concerning airborne . spore diffusion and to determine if cross contamination is occurring between two separate areas. The collection of air samples is attained, in accordance with the commonly accepted protocol published by the American Industrial Hygiene•Association. Sample locations were chosen to give a representation of existing baseline conditions throughout the site. Non - viable air sampling was performed using Air -O -Cell Cassettes. The Air -O -Cell Cassette utilizes, spore - trap technology for the microscopic analysis of fungal spores, pollen, dust particles, and fibers. Most • common fungal genera can be positively identified including Stachybotrys spores. Fungi such as Penicillium and Aspergillus can also be identified, but may be grouped together as indistinguishable. The sampler was used with the conventional method of calibration by mounting a rotameter to the pump and adjusting ,the flow rate to 15 liters per minute (Ipm). To prevent cross contamination during sampling, the tubing was cleaned between every use. Standard laboratory alcohol wipes were used for this procedure. Field personnel thoroughly wiped the top and the backside air inlet (venturi) on the top cap to prevent any contamination between sampling episodes. The results are reported as total, meaning they include both viable and non-viable fungal spores. Current Exposure Guidelines: In the United Sates, no federal. agency has clear authority to regulate exposure to biological agents associated with building related illnesses. Countable bioaerosols have no • Permissible Exposure Limits (PELs), or Threshold Limit Values (TLVs) for the following reasons: the culturablelcountable bioaerosols have no single entry; the human response range varies greatly from one individual to the next; it is not possible to collect and evaluate all bioaerosol components using a single sampling method; and the information relating bioaerosol concentrations to health effects is generally insufficient to describe exposure response. • • Due to the wide variety of microorganisms found across different regions of the United States and the influence of normal humidity and temperature conditions, the concentrations of bioaerosols vary significantly • from area to area. With the absence of exposure limits, it is common industry practice, as supported by the • • American Conference of Governmental Industrial Hygienists (ACGIH) and 'the Environmental Protection . Agency (EPA) guidelines, to compare outside bioaerosol concentrations and species to inside bioaerosol Pacific Environmental Company 8 • • concentrations and species. Generally speaking, the indoor air flora should be quantitatively lower than, but qualitatively similar (genus or species) to that of outdoor air. In this inspection, areas of contamination were identified through comparison to outdoor bioaerosol control samples, visual identification of impacted materials, and bulk sampling. • • Sample Results • A total of thirteen (13) non - viable spore trap air samples were collected and submitted to the laboratory for mold analysis. Outside air samples provide better background information for comparative analysis as a • control. Molds were identified by direct microscopy, a method that counts both viable and non - viable spores to derive the total spore count. Microbial sampling indicates evidence of aerosolized contamination in Room 8 and within the wall cavity below the sink in Room 5. • Air sampling results are limited in that they represent airborne concentrations at the time of sample collection only. Changes in operating procedures, ventilation, temperature, occupancy, and other conditions may cause variations in anticipated airborne concentrations. The individual sample results are detailed in . . _ the appendices. • • SUMMARY Asbestos • • The results of the air samples collected indicate that at the time of sampling, there were no asbestos structures detected in the ambient atmosphere inside of the building. While this indicates a low potential for • exposure at the time of sampling, it should be noted that the conditions can change with activity or occupancy. In order to prevent the possibility of future exposure, the damaged ACMs need to be removed • by an asbestos abatement contractor prior to re- opening the facility. Due to the condition of damaged ACM at the site, asbestos fibers could be released in the event that the damaged ACM is disturbed and /or the building is reoccupied and interior air circulation /movement increases as a result. • Repairs to the roof are necessary to prevent further delamination of the acoustic ceiling material. We observed damaged plaster /acoustic materials in several locations, notable the south end of the corridor in Building A, and one of the classrooms in Building B. At these locations, delaminated ceiling debris was noted on the floor The vinyl floor tile in the corridor of Building A is in such poor condition that we would consider it to be friable. Even though there is carpet (which appears to have been installed as a temporary precaution, i.e. • laid loosely over the floor) over the damaged tile, PEC classifies this as a hazard which should be remedied prior to re- opening the facility to the public. • Pacific Environmental Company 9 • • Asbestos must be handled in strict accordance with the various federal,.state, and local regulations. Failure to abide by these regulations can result in penalties to both the contractor as well as the owner. All asbestos related work must be completed in accordance with the following regulations: o South Coast Air Quality•Management District Rule 1403 Requirements o National Emissions Standards for Hazardous Air Pollutants, 40 CFR 61, M o Occupational Safety and Health Administration, Asbestos in the Workplace, 29 CFR 1910.1001 o Occupational Safety and Health Administration, Asbestos Construction Standard, 29 CFR 1926.1101 o Title 8, California Code of Regulations Section 1529, Cal -OSHA Construction Standard All asbestos waste must be properly disposed of and documented. Waste Manifests must be submitted at • the end of a project. Disposing of a known hazardous waste is illegal in the State of California. Lead • Defective LBP has caused this site to be contaminated with lead dust, with the exception of the Fun N' Sun portion of the building. Testing for blood lead levels of the children attending and staff of the facility should be made available to those who have concems. It should be noted in the report that while the windows were not open during this evaluation, they were nearly all open during our initial visit. The window sills are at a height that any child at walking age would be able to reach. Since the windows are usually open, the lines between 'interior and 'exterior' sills are blurred. Many toys, tables, and other play items were located directly below the windows. All of the defective "loose and flakey" LBP should be treated (stabilized or removed) to prevent potential lead dust exposure to occupants of the facility. Non - porous items located at the facility; such as furniture, plastic toys, etc. should be decontaminated while the porous items; such as bedding, chairs, etc., should be disposed of based on the elevated lead dust levels. All lead related work should be completed in accordance with the following regulations. o Title 17, California Code of Regulations, Division 1', Chapter 8: Accreditation, Certification and Work Practices for Lead -Based Paint and Lead Hazards. o Title 8, California Code of Regulations, Section 1.532.1: Cal /OSHA Construction Safety Orders, • Lead. o "Guidelines for the Evaluation and Control of Lead -Based Paint Hazards in Housing," US Department of Housing and Urban Development, June 1995 • o Use only California Department of Health Services Certified Lead Workers and Supervisors to • perform lead abatement. All Certifications, Respiratory Fit Tests and Medical Releases must be on- site at all times when lead related work is being performed. • • Pacific Environmental Company 10 • • o All waste generated from any lead related work must be properly profiled and disposed of. Waste manifests documenting the disposal site will need to be submitted at the end of each phase of the job. • Mold Contamination Please note that our findings and recommendations are based on our observations, moisture analysis and analysis of available testing data and laboratory results. Any irregular health related symptoms suspected should be discussed with a physician. This report is based on the conditions at the time of the inspection. Microbial sampling indicates evidence of aerosolized contamination in Room 8 and within the wall cavity below the sink in Room 5. Pacific Environmental Company recommends remediation of the potentially fungi- contaminated building materials below the sink in Room 5. The impacted wall behind,the.cabinetry should be opened up, utilizing appropriate engineering controls, to evaluate the source of water incursion and to remove any impacted materials. • We also recommend that all ceilings be removed in the areas that show indications of water damage and that the ceiling system and substrate materials be evaluated to determine the extent of contamination. Since the ceilings are covered with asbestos- containing acoustic, remediation should proceed as an asbestos abatement project. Once the remediation is complete, and.prior to replacement of the removed building materials, an inspection of the work should be conducted to verify that the impacted materials have been removed. Air sampling should be conducted to verify that the air concentrations are within acceptable limits. All work should be conducted using HEPA filtered negative air machines, which must be exhausted to the exterior of the offices. Remediation activities should be conducted in accordance with EPA guidelines. Our recommendations are intended to remove water - damaged building materials from the affected area and reduce the potential for future aerosolization of identified contaminants. LIMITATIONS • The conclusions and recommendations presented herein are based upon the agreed scope of work outlined in this report and were necessarily limited to the information provided by, the samples collected and laboratory analysis completed. Pacific Environmental Company makes no warranties or guarantees as to • the accuracy or completeness of information provided or compiled by others. This report is not a legal opinion. The services performed by Pacific Environmental Company have been conducted in a manner consistent with the level of care ordinarily exercised by members of our profession currently practicing under similar conditions. No other warranty, expressed or implied, is made • • • Pacific Environmental Company 11 Appendix A Site Photographs -..7-",7".-..: t .'l L y " d'+'"),), f t 'A a .- f *- & d_ m3- y s � °' `x' u` ` _4;i i� to .; +� (_' 2 I $ k � yv y , � "7,: • z•11',-:.. °i JL t p i ' . •1tn�' : j : r 3 ' -� i '� y1r rri i .._. . ..=s I b Damage asbestos - containing acoustic. r: -. s I '1+' 'ma s I 4 i t ' `u ck ., h s ri k n 5 ' . ?., ; • 41. • .- , ' G �� X ,.�, K �� -� � ...A.,- { --i --4,-,-.-:_•-...-4,..--.. # E fi M J "� 4 +�, IS f-ri t b r r f i 'gs"' ,yy,, �r s �. e ` F' . -f ^fin . ..=' 2. --,--t-7 ..* ri,- '" y j• a:, 7 - m.. . c ' � 'gfr ,, ` ' r i, v s ry e } # s [ T -fit. I '"`7i � p F .; ar ,Ct _ :. t x i . �. ' = Y ".hu 1 5 f a '-'--1 - ? .- i' ,fife N ay �'r ,...7t, b x0 . x Y� } I .1 _, i 44-,AD. •+. : -..,.,',1 " -,,,,,, -- , 17 ; ,-, m a r l • Damage asbestos - co ntain i ng flooring. a 4' 4 e m . 0 . r Y % ri Jt� Yak ' : S" ! ' '. w # ( ' S x. 1r i` - f iL '`"` ,, ! A C k n "- ' .' # Y `r. .�,U' • wu- ' t 3 � s 'y . ` � J :Jr,' �v. � c}a � w ry $7, �'r� ,f�.i . '! ,, 5 5 , » - M m � . .xR' y id :" `'Sy � i > ' 4- �9 . d e .. iT. ' P C . ' � . } a ti " fa ; „ f£ .+ s '�'r ..Y+, s` 4 .- �'z*i� -it + ; . Damaged asbestos - conta flooring. #„ y _ pp3�",. -a *'.-'' -.1,-r-,7-1;—!=c. Lc S.d” s�sT 1 ° �5:'. y *i �S kAg, >,tr -ti ' - t` 1 r ,.- ray t S ra" ''.` it i c- t vx l` \ r ,ta 2r " ` C 4- 4,-4 Yn' ` 1t-r to -1 f 1 b" r 4.. a k ^ ^ .'- fix: Tt - l ` r) - - _ , :i i � v i.a} +yE''d z ° I,° _s f r � . "' • + 7 `�. v i * r '.. 4: o `" .- .3"""a f 4' rn � ;, ,.; �; R - • . g : - r ,,. �'� h a-xk. t x xn .. r �. -' ,� s .:r - .-_^?t.. k R ,fly f,/ ,o s a s s J a �� s tY'u. w- >.3` ; ,r ' � . �' ,- h i f 4y ' i_,+ � A L t c "t Z s v..;_ a �i :^ } > t r ,' _ § $ #t .- 3i.,�,'. "M:'; ;. T t #.^.�.iriVI l"S a { e"-�lq X YES. -mot-- .. T ' Y-" ", [ 5.33:;:#4.127'1"• taf I 5 ..,- y . `}' 7 1 Iv„ t 3' i., � �{f ,. ." k i : K G4 a Damage a sbestos - containing floo . o 4 b Appendix B Site Sample Plans • 024 • 043 ROOM 5 (OFRm) ROOM 1 (8) A /` 019 .023 • 020 ,. 045 ROOM 6 (Lounge) ROOM 2(9). BUILDING "A" .022 ROOM 2 (15) 038 ROOM 3 ot6 .047 021 • RR 026 ROOM 4(11) • 025 049 • RR • • • 1 027 BUILDING "B" 039 • 029 ROOM 8 (29 ROOM 9 (18) ,051 • 032 SUN Pr FUN ROOM ID (19) ROOM 11 (17) RR RR 02% 030 • 031 • 042 Q DATE PREPARED; DRAWN BY: TITLE_ • t" [ �� g @ 10 -15 -2004 M.L. �� L * C 6 F E REVISION NO.: REVISION OARS: - ENVIRONMENTAL SAMPLE LOCATION PLAN • • y n PROJECT NO. APPROXIMATE SCALE: INTERIOR /EXTERIOR DUST SAMPLES • 04193 • 1"=30' FIGURE No. PROE.C'NAME PREPAPEDFOR y Indicates Sample Location Zoeter School, 357 12th Street, Se& Beach, CA TEC Engineering /AJ 035 . 044 ROOM 5 (Office) ROOM I (8) • •046 ROOM 6 (Lounge) ROOM 2(9) BUILDING "A" ROOM 7 (15) 037 • ROOM 3 (10) • .048 RR ROOM 4 (11) 050 RR 038 a w z • BUILDING "B" 040 034 - • • ROOM 8(20) ROOM 9(18) {� ,036 • • i • SUN 14' FUN R0. RR ROOM 10 (19) ROOM 11 (17) • 041 DATE PREPARED: DRAWN BY: TITLE: P CI 1V 15lO -1 ry NO.5 -2004 M.L. _ 4 0. E : REVISION DATE: a' D ENVIRONMENTAL SAMPLE LOCATION PLAN o PROJECT NO. APPROXIMATE SCALE: EXTERIOR FLOOR AND SURFACE 04193 1 " =30' DUST SAMPLES PROJECI NAME - PREPPED FOR FOURS NO. .Indicates Sample Location Zoeter School, 357 12th Street, Seal Beach, CA TEC Engineering J • 001 002 004, ROOM 5 (Office) ROOM 1 (8) ' 003_ ROOM 6 (Lounge) ROOM 3 (9) 010 • BUILDING "A" _ 009 • ROOM 7 (15) 005 - ROOM 3(10) 008 RR ROOM 4(11) 006 RR 007. 0 .11 3 C m BUILDING "B" 016 •013 -018 ROOM 8(20) ROOM 9(18) - 015 .017 SUN N' FUN 1 ? RR RR ROOM 10 (19) ROOM 11 (17) •014 .012 • Q DATE PREPARED: DRAWN BY: TITLE 10 -15 -2004 M.L. 1 > < P PAC E F REVISION NO_ REVISION DATE: b ENVIRONMENTAL SAMPLE LOCATION PLAN R PROJECT NO. APPROXIMATE SCALE: INTERIOR FLOOR DUST SAMPLES 04193 — PROJECT NAM.. U PREPAR FOR FIGURE N0. Indicates Sample Location - Zoeter School, 357 12th Street, Seal Beach, CA TEC Engineering Attachment B: October 26, 2004 Letter to Under the Rainbow Agenda Item mrow» -.?' �.9?"- �.. �, i .,} .� i' 'x.>'"egb N ; . m , 5'� • V Veie 4 511k'�" W 54,�4C 'e z`�. y.ae ai.•'x" �' �^ 'A : " Ya £t : V ; .c 4as. 4 V .. `t. c r r^ sn. kF� t ft' `s jv i " •7+� --ac- Q y Y 2 M . '. ° 'a 'FRw. a f -r. Y ; z: r ' x, 4 � 9f ex ^ w r y f ' � • T i - # ' �: - <1 ;:: . S w :I Lr a £EG T ,t 'k y sy i e i },Y ..}. 4 Y.r.r a ��.* a1 sx"-. of ti y o-E.` !I .x�- � f� p i '-'T x t x: u£ }�. G w 4 +Yv n A ' So- t gL ` s p i, l S Ca x, w e QiGp j n :.: : ,� },,,, a i h M } 2 t ' ,a W S r y 'v^' x a :: ^ G $ ' , y +. ,.. �r 4 x ; .. Ft w',*"r` 1 ."'i 3' c. T.e - t ' r n e -, r ✓ rt �FCen'M'iC.:w4aa T �. �`° „v.F° �v `' �•✓3,#�W c a � i �r'~�'ir.. �" xap� i � y 7 + * ,,'1 Zt'A✓+.w�A� � u�t'"' CC CFAT RFAF'N%CATIF(IYRIFG lQ74� s -as_ 'c. ; '. ` 7,,, g.`4. { ',C n isi ry - g t w tai i s. taw r` � , a 1 � � -a �-yt w s+ `�- -.,. ' � n:3i m- 'Yn,4,!+ < ;�vS'+. v,.k" -r�tlk .: ma .. e, �W W.CG�- tIPSCt4CdLL4: -s-F s'. - ry '�..r: ri '?�'.4'.K3'�a: 'z".`' _ 8sfr rrT,s;". _3.ii. ,NS<a'"SA a�.; a ,. ??yy -, .fi..ii ...Hj: a "". y °em ca 1bc weir's' r y ,. $� K- ., c: ,,, .tt a _-04- .. - e ` 42tW ... k,,s '1t' ,., s'. °`v ..; ,.. �d f6 R. ': „„„t„,.„, VIA U.S. MAIL October 25. 2004 Under The Rainbow 357 Twelfth Street Seal Beach, CA 90740 Attention: Ms. Debbie Daniella Re: Notice Dear Ms. Daniella: On September 27, 2004, the City of Seal Beach informed you that it had received a survey report from an environmental testing firm which disclosed the presence of asbestos containing materials (ACM) and lead based paint (LBP) in the buildings at the former Zoeter School site, located at 357 Twelfth Street, and at which Under The Rainbow operated a daycare center. Although .we understand that the presence of these materials is common in older buildings, including many school facilities through Southern California, the City decided that further testing and assessment at the site was necessary and we notified you, as the operator of Under The Rainbow, of this situation. The City also committed to keep you and the parents of children attending the center fully informed of the results of the environmental assessment and any further action regarding. the Zoeter School buildings. . Since our September 27 notice, the City conducted further testing in the buildings occupied by Under the Rainbow. That testing has confirmed the presence of ACM and LBP in the buildings occupied by Under The Rainbow. Pursuant to California Health ' and Safety Code Section 23915.5 and other applicable statutes and regulations, a copy of the enviromiental assessment results will be mailed to you under separate cover. We have also had those results reviewed by Meredith & Associates, an environmental consulting firm that is assisting and advising the City with respect to potential health risks relating to the presence of ACM and LBP at the facilities. Meredith used the assessment data as input for two lead risk assessment models that are designed to predict blood lead levels in children that could result from exposure to lead in dust, paint, or soil. Both . models were originally developed for use in residential settings. To better reflect the ( I s • conditions at the site, and consider the effects of exposure the school, the models were modified. The modified models predicted blood Lead levels below the Centers for Disease Control and Prevention (CDCP) threshold. • These preliminary evaluations notwithstanding, the EPA's nationwide Lead Awareness Program states that the only conclusive way to determine if a person has been adversely affected is with a blood lead test. The test is simple, quick, and available through family physicians or nearby health centers, who can help explain the results. We ask that you relay this information to your employees and to the parents of, children attending your daycare center. People who do not have a doctor may call the County's Health Referral Line at (800) 564-8448. • - Additional information may be found at the following EPA, HUD, California Department of Health Services, and Orange County Health Care Agency web sites: htto://wwv...ena..govionetintrilead/leadpbed.htm http: www.hud.cloy/offlces /lead /index.cfm • lattn://www.dhs . c a.2o v /chi ld lea ct! httty://www.ochealthinfo .c om/mcahlchlppo.htm • To help you notify the parents, we are sending copies of this letter to the parents listed on the roster given to us on September 28, 2004. We ask that you re- notify the parents of • the children attending the daycare center and notify all employees of Under the Rainbow of this letter and the presence of ACM and LBP at the facility. Please contact me if we can provide you with additional information regarding the environmental assessment results or if we can be of further assistance. • Sincerely,- • • Mark Vukojevic, P.E., Interim Director of Public Works /City Engineer • • Copy to: Mayor and City Council City Manager City Clerk Under the Rainbow Parents - Chron File • Attachment C: Preliminary Alternatives for the Zoeter School Property Agenda Itemn N (6 N o 0 , > " 3 0 0 O °- N C a) O 7 0 @ Y C 0 o E O rn.0 a) p t_ o ° C c O) i C a) ""' C O N '� a) 7 O @ E 0) a 16 O a) g o N a) a) ° 0 C 0 CO N X � r- N .0 . f/) a) 0 N_ a) °` ° N y a) 3 u) 0 @ y Q 'O @ N O o N a O a @ ) N LL ' CO Q O� 3 �U 2U >, to L -0 • • • • • • • Q O N @ @ a) @ N o 2 a a m a m T co O CO Q) a) a) a a) To a EA c 01 - ° @ '0 @ ._ - c d_ O o C° O N O ° � O @ 0 L ' 0 >' 2 i L - 0 7 cq o °u > Via) "Q) E C E 2 o m N <@ C@ @ h w CO o o E @ ° , m O w Q° E c a w c) v o ° ul .� c c o �_ > a o > Q a ° @ 0° 2 0 o C n 0 co 0 2 0 co Z a) o d - • • • • • • • • N • N 0 o a) p co _c ,_ a) 2 a) N a) O 0 0) C N a) O r as > O dj E 0 0 O 0 c Z @ O o E a) 4- 6 co o 00 00 00 0o 00 00 O To ti v coo 0 o0 o0 Q t y . O N E Cr 0 0 0 0 0 0 0 �, co O - 00 � "U° OO CD O CO CO 3 0@ a V .71- N N M •V r N" E EA EA 69 EA fA EA EA fA 0 m N 1 • 1 co ∎ (n E ll n @ .. r a) _c 7 N C C C C (n 0 a) a) . y 0 = 0 a) >.i- o E,c E > E Q E a = E °o a) p V 0 a) U > @ 4 0 -@ 0 +' @ N w CO 1. .44 iri <0E00° R @a) al co y° ci @u� — ca v CD d o x = m 2' 2 w , @ LL a ) N LL a) N LO m � o m m a °° LL ° 0a- `� E� > x c :o s o (/) - 0 O @ N� o o � 2 Lo m o a Rii m S> m @.0) ° o co c o o m c c > @ — ( o a) c R o c ? o -° tC O . O O O m c N >N@ O T O w E N E a =0_0 7 O V '� C 02 ` CC - o @ aEL <C u� 3 .0 E o ca ci) a - -I ai 2 E o u -< 2 Z Q - ° o Q ZQ a_ L • • • • L 0 0 Z , N a) v N N ti O V) ° N N O) N C O Q c - O C O .. U co a3 Q a3 ' a) o 5 o C O N R O) d a) O O 7 a) a) a) L 1_ C `- L C R O > O C N V n3 d1 - a) co Y cn 'cn 0 3 N A O — tn Q) R 0 a) - C O R a) U O 4) j' a) 0_._ a N� �a'OO • N'O O Q O E U X O C o L a) O co— Eg c6 ZJw W U O Z amZ • • • • • • • • • • N w 0 � a) 0 y C co @ C O a) >, CO CO N = a) ca 7 0 " — O U E o 0 - U U E 2 _ O i O w O. O - O U O a 'O Ti) U y U CO 3 0 U O O C O N • a) O O . . . N ° @ C C C R C R C m 0 t • R a) - >+ a) E O O D C N O N Ct 0 j o •'p (6 0 E E :p O 0 ° U E 'D E co CU 43 0 m ° n O° Q a mO Qa o • • • • • • • • N 0 r 0 N 0 0 cz C o O O O � O cp c0 O 0 0 O O O O Q O O O O O O O O O O O O O O O O CU 000 (DO M� (D[0 C 'E 64 69 69 69' 69 (A EA ({3 0 a) N CL '-= C O C O • w C ) C E E m a) E (o Q E E R E 'O Ti L O a) r Y E a) 3 >` E a) 0 E a) 0 L O) d .. c0 N R ( , C - — O cz 0 '7 - Q O N o5 O O_ ` O y R U 0 y CO U . L co U C Q CO in -O 7 C d "O 0 7 2 'O O Y 'O a et , L > L L L L C 3 - o R— C C C C Q. `t 7 '0 O O C t O a V - o O O d ' O . . C U L .0 I- C °` > C U U U@ a) m R c R ao .R.. a) E R •. a) _ T R C T L . N 0 7 t to p 0 C to co C U) O R R O :■•. "O R Q O : .. 'O O O Ira O CO $ - O. �� o m �E �a�ioE c a a) ) ° m a — R O E E m E N O N LL O Q N m LL O N a) O a) r 2 Q "O co 5 U)I Q 'O co O Q "O U 0 Q 'O .0 in co h co