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2141 Mission Street, Suite 100 | San Francisco, CA 94110 | 415.391.2510 1520 Brookhollow Drive, Suite 30 | Santa Ana, CA 92705 | 714.541.5303 AllWest Environmental | AllWest1.com AllWest Environmental ENVIRONMENTAL SITE ASSESSMENT 3169 Red Hill Avenue, Costa Mesa, CA 92626 PREPARED FOR: Client Name Address City, State, Zip ALLWEST PROJECT xxxxx.20 Date PREPARED BY: Preparer's Name and Title REVIEWED BY: Reviewer's Name and Title

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Page 1: AllWest Environmentalallwest1.com/projects/reports/industrial.pdf2016 AllWest Asbestos, Lead & Hazardous Materials Assessment ... Costa Mesa Fire Department and Orange County Environmental

2141 Mission Street, Suite 100 | San Francisco, CA 94110 | 415.391.2510

1520 Brookhollow Drive, Suite 30 | Santa Ana, CA 92705 | 714.541.5303

AllWest Environmental | AllWest1.com

AllWest Environmental

ENVIRONMENTAL SITE ASSESSMENT

3169 Red Hill Avenue, Costa Mesa, CA 92626

PREPARED FOR:

Client Name

Address City, State, Zip

ALLWEST PROJECT xxxxx.20

Date

PREPARED BY:

Preparer's Name and Title

REVIEWED BY:

Reviewer's Name and Title

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TABLE OF CONTENTS

I. EXECUTIVE SUMMARY ...................................................................................................... Page 1 II. CONCLUSIONS & RECOMMENDATIONS ......................................................................... Page 3 III. ENVIRONMENTAL PROFESSIONAL'S DECLARATION ................................................... Page 4 IV. SCOPE OF WORK AND LIMITATIONS .............................................................................. Page 5

V. ENVIRONMENTAL ISSUES MATRIX .................................................................................. Page 7

VI. ASSESSMENT FINDINGS ................................................................................................... Page 8

A. General Information ............................................................................................... Page 8 B. Physical Characteristics ........................................................................................ Page 13 C. Natural Hazards ..................................................................................................... Page 14 D. Site Characteristics ................................................................................................ Page 15 E. Hazardous Materials in Facility and Operational Systems ..................................... Page 16 F. Toxic and Flammable Materials, Compressed Gases and Petrochemicals .............................................................. Page 17 G. Pollution Sources, Controls and Treatment ........................................................... Page 19 H. Regulatory Database Search ................................................................................. Page 22

VII. INFORMATION SOURCES ................................................................................................. Page 29

ENVIRONMENTAL ACRONYMS

FIGURES Figure 1: Regional Map

Figure 2: Vicinity Map Figure 3: Aerial Photograph/Site Plan PHOTOGRAPHS 1 through 28 APPENDIX A EDR

® Reports

Radius Map Aerial Photo Decade Package Certified Sanborn Map Report Historical Topographic Maps City Directory Abstract

APPENDIX B Completed Environmental Questionnaire APPENDIX C Selected Previously Prepared Documents

1989 Hekimian & Associates, Inc., UST Closure 2013 Weston ESA

2014 Weston Phase II Assessment 2014 Weston Hazardous Materials Inventory 2014 AllWest Phase II Report Peer Review Summary 2014 AllWest Beryllium Sampling Report Peer Review Summary 2015 Weston Phase II Follow-up Assessment 2016 Weston Excavation, Decontamination and Demolition Completion Report 2016 AllWest Asbestos, Lead & Hazardous Materials Assessment 2016 AllWest Environmental Documents Peer Review Report 2017 AllWest Beryllium Remediation Report 2018 Weston Decontamination and Demolition Completion Report

APPENDIX D Report Author Credentials APPENDIX E Authorization for Reliance and General Conditions

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ENVIRONMENTAL SITE ASSESSMENT

3169 Red Hill Avenue, Costa Mesa, CA 92626

I. EXECUTIVE SUMMARY

AllWest has completed an environmental site assessment of the real property referenced above. This assessment was performed in accordance with the scope and limitations of 40 CFR Part 312 Standards and Practices for All Appropriate Inquiries; Final Rule, and ASTM E 1527-13 Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process. Any data gaps, exceptions to or deletions from these practices are described in Section IV of this report. AllWest conducted a site visit of the subject property on [Date]. This executive summary is provided solely for the purpose of overview. Any party who relies on this report must read the full report. The executive summary may omit details, any one of which could be crucial to the proper understanding and risk assessment of the subject matter. The subject property, Trico Pacific Center, is developed on two contiguous rectangular parcels comprising 5.366 acres (233,743 square feet), designated as Assessor’s Parcel Numbers (APNs) 427-011-03 and -04. Located on the west side of the intersection of Paularino and Red Hill Avenues in Costa Mesa, the parcels have approximately 540 feet of street frontage along Paularino Avenue adjoining northeast and 413 feet of street frontage along Red Hill Avenue adjoining southeast. The property originally included three buildings, all constructed between 1967 and 1970. The Main Building, also known as the Red Hill Building, is an approximately 63,290-square-foot, two-story structure with two mezzanine areas at 3159 – 3169 Red Hill Avenue. The Paularino Building, also known as the CIM Building, is a single-story structure of approximately 24,000 square feet at 201, 205 and 225 Paularino Avenue. The Hot Press Building was a single-story building including 12,000 square feet. Addressed as 235 Paularino Avenue, this building was demolished in 2016.

The subject property was under construction during our site visit. The subject property was most recently occupied by Ceradyne Advanced Ceramics (Ceradyne), which manufactured ceramic body armor, helmets and armor plates for vehicles and helicopters, as well as ceramic medical and dental products. 3M acquired Ceradyne in 2012; Ceradyne ceased operations at the facility between 2013 and 2016 with the exception of Suite 3161 where 3M still operates a ballistic testing chamber. 3M remains the party responsible for final disposition of the Ceradyne facility. The zoning designation for the subject property is MP – Industrial Park. The subject property is located in a commercial area of Costa Mesa. Adjoining properties include commercial offices to the north, south, east and west. Subject site topography is generally level, at an elevation of approximately 46 feet above mean sea level. Vicinity topography slopes very gently towards the northwest. Groundwater depth is approximately 40 feet beneath ground surface with ground water flow direction documented to the south/southwest.

AllWest assessed the site’s land use history by reviewing aerial photographs, city directories, topographic maps and other relevant documents. Our review indicates the subject property was undeveloped, or possibly agricultural, prior to site development. Property tenants initially included several commercial and industrial occupants, including electronics and semiconductor manufacturers, a photographic and printing facility and a camera manufacturer. Ceradyne, the most recent building tenant was the sole occupant of the buildings from 1985. Hazardous materials were not observed on the subject property during this study, with the exception of those utilized in building renovation activities. Previous property occupant Ceradyne utilized hazardous materials and generated large quantities of hazardous waste in their manufacturing processes on

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the subject property. Hazardous materials documented at the Ceradyne facility included acetone, methyl ethyl ketone, alcohol, propane, lubricants, trichloroethylene (TCE), metal plating solutions (acids, caustics, metals and cyanide) and beryllium. Numerous waste streams were documented, including flammable solids, lead-contaminated plates, flammable liquids, caustic soda, clarifier sludge, oily water and others. A 1,000-gallon gasoline underground storage tank (UST) was removed from within a drum storage area on the southeastern portion of the 201-235 Paularino Avenue portion of the property in 1989. Petroleum hydrocarbons reportedly were not detected in two verification soil samples collected following tank removal. Costa Mesa Fire Department and Orange County Environmental health observed the UST removal. Three below-grade separator/clarifier systems were formerly present at the Main Building on the subject property, associated with former tenant Ceradyne’s manufacturing activities. The separator/clarifier systems reportedly discharge(d) to the sanitary sewer; discharge permits were stated not to have been required. Petroleum hydrocarbon-impacted soil was documented beneath the interior eastern Main Building separator/clarifier in 2013; following excavation of the impacted soil, the former clarifier location was backfilled with sand-cement slurry in 2016. Sampling of the contents of the western interior clarifier reportedly revealed it to be non-hazardous; the clarifier was removed during construction activities. The exterior separator/clarifier was also removed in 2018 during construction activities. Ceradyne also operated an “above-ground sump” in the Main Building at the property, which facilitated collection of fluids generated during use of a trichloroethylene (TCE) degreaser in their manufacturing operations. The unit no longer is present at the subject property; no information on associated removal activities was available. Soil, soil gas and ground water quality investigations were conducted at the subject property beginning in 2013, to identify whether former manufacturing activities impacted the subsurface. Based on the available information, it does not appear that regulatory agency oversight (CMFD or OCHCA) was requested at any point during the investigations or subsequent remedial activities. No volatile organic compounds (VOCs), semi-volatile organic compounds (SVOCs), total petroleum

hydrocarbons as gasoline (TPHg) or cyanides were detected in the soil samples collected from the vicinity of the exterior separator/clarifier, the interior separator clarifier in the eastern portion of the Main Building, former TCE degreaser area and former gold plating line area. Total petroleum hydrocarbons as motor oil (TPHmo) were detected in the vicinity of the clarifier in the eastern portion of the Main Building, at concentrations of up to 3,170 milligrams per kilogram (mg/kg). During facility decontamination and demolition activities in 2016, soil removal was conducted beneath the clarifier. One confirmatory soil sample was collected from the bottom of the excavation; no petroleum hydrocarbons were detected. Concurrent with the soil quality investigation, soil gas sampling was conducted in the Main Building in 2013, including collection of samples in the vicinity of the exterior and eastern interior clarifier/separators, former TCE degreaser area and former gold plating line area. TCE concentrations exceeded the California Department of Toxic Substance Control (DTSC) California Human Health Screening Level (CHHSL) in two samples in the southern portion of the former TCE degreaser area (3,100 μg/m

3) and northwestern

portion of the former gold plating line area (7,900 μg/m

3). 1,2-dichloroethane (1,2-DCA) also exceeded

the CHHSL in one sample (270 μg/m3).

During facility decontamination and demolition activities in 2016, soil removal was conducted in the vicinity of the former gold plating line area in the Main Building. One confirmatory soil sample was collected from the bottom of the excavation; no VOCs were detected. There does not appear to have been soil removal conducted in the former TCE degreaser area. During our 2014 review of the soil and soil vapor data, AllWest recommended sub-slab soil gas sampling in the vicinity of the former TCE degreaser and gold plating line areas, as the source of TCE in soil vapor did not appear to have been identified. AllWest opined shallow soils surrounding the former TCE degreaser and gold plating line areas in the Main Building had not been adequately characterized to identify the potential source area of the TCE in soil vapor. Based on this data interpretation, the potential for a Vapor Intrusion Concern (VIC) from Ceradyne operations is assessed as moderately low. Collection of four ground water samples from temporary wells was conducted by Weston in 2013. Although the samples all were collected from exterior areas on the Main Building portion of the property, locations included one sample from the up-gradient property boundary, one from the down-gradient

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property boundary and one nearby down-gradient of the former hazardous waste storage area. No VOCs, beryllium, lead or petroleum hydrocarbons were detected in the groundwater samples. No significant quantities of SVOCs were detected in the groundwater samples. Between 2016 and 2018, decontamination, demolition and confirmation activities were conducted at the subject property, including wipe sampling for clearance of equipment and building areas (including Beryllium Oxide [BeO] sampling), decontamination of equipment in Hot Press Building, decontamination of the former grinding area/mezzanine and demolition of the mezzanine in the Main Building, and decontamination and demolition of the Hot Press Building. Regulatory agency oversight of the decontamination activities was not documented in the record. In previous reviews, AllWest concluded that, based on the project observations and confirmatory wipe sampling data, BeO contamination was successfully remediated from the Paularino Building (Suites 201, 205 and 225) and Main Building (Suites 3159-A&B, 3163, 3165 and 3169-A&B). AllWest also concluded, all exterior outbuildings along the western wall of the Main Building, former hazardous waste storage area and parking lot between the Paularino Building and former Hot Press Building were successfully remediated. Since the Hot Press Building was demolished, confirmatory wipe samples were not collected. Sampling conducted on the interior and roof of the 3161 Main Building suite identified one light fixture, five roof mounted HVAC and/or exhaust fans with a beryllium concentration exceeding the clearance level. The final disposition of the light fixture and roof mounted equipment reportedly remains to be addressed by 3M. Following completion of the decontamination and demolition project in 2018 the contractor concluded that no additional further action was warranted at the subject property. As part of the decontamination, demolition and renovation project on-going at the subject property, asbestos sampling and abatement was conducted. Asbestos was identified within the joint compound and wall texturing. Information included in the Weston 2018 decontamination/demolition completion report documented removal of roofing mastic, followed by removal of the asphalt rolled capsheet down to the plywood on all building roofs other than that at 3161 Red Hill Avenue. ACM abatement for the identified interior materials, specified by AllWest, was conducted at that time as well, with visual and air clearance confirmed following completion.

Lead-based paint (LBP) sampling conducted at the subject property at a similar time did not document the presence of LBP. To identify the site’s potential inclusion on environmental databases and evaluate off-site environmental concerns, AllWest reviewed a site-specific radius report provided by Environmental Data Resources, Inc. (EDR) which searched regulatory agency lists/ databases for recorded sites within the industry standard search radii. For generation and disposal of manufacturing-related hazardous waste during previous occupancy of the subject property and disposal of asbestos-containing waste, former subject property tenant Ceradyne and/or current property owner were listed on the RCRIS SQG, Haznet, FINDS and ECHO databases. For the gasoline UST previously located on the subject property, current property owner was listed on the UST database. For air emissions related to manufacturing during previous occupancy of the subject property, former tenant Ceradyne was listed on the EMI and FINDS databases. For permitting related to disposal of industrial wastewater from previous on-site manufacturing activities, former property tenant Ceradyne was listed on the EnviroStor and WDS databases. Finally, for storm water management under NPDES permitting, former subject property tenant Ceradyne was listed on the NPDES and CIWQS databases. EDR’s agency database search identified the subject property on multiple databases. However, the listings were not on databases indicative of a release and generally were indicative of appropriate waste disposal practices. For this reason, the listings alone are not indicative of concern to the environmental condition of the subject property. The listings document hazardous materials use and hazardous waste generation at the Ceradyne facility.

The agency database search found no surrounding or adjoining sites that appear likely to have significantly impacted the soil or groundwater underlying the subject property.

II. CONCLUSIONS & RECOMMENDATIONS

AllWest has conducted an environmental assessment for the subject property in general accordance with 40 CFR Part 312 Standards and Practices for All Appropriate Inquiries; Final Rule, and ASTM E 1527-13 Standard Practice for Environmental Site

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Assessments: Phase I Environmental Site Assessment Process. We have identified two Recognized Environmental Conditions (RECs) and two Historical RECs (HRECs) at the subject property; no Controlled RECs (CRECs) were identified. The first REC is associated with the TCE and 1,2-DCA impact in soil vapor in the vicinity of the former gold plating line and TCE degreaser areas. Based on the available soil and soil vapor data, confirmation of adequate removal of residual TCE in site soils and mitigation of potential vapor intrusion risks to building occupants has not been fully addressed. The source of TCE in soil vapor has not been identified. Additionally, shallow soils in the former TCE degreaser and gold plating line areas in the Main Building have not been spatially characterized. Soil, soil gas and/or indoor air quality sampling is recommended in the Main Building, in the vicinity of the former plating line/degreaser and TCE degreaser, as well as in the location of the former above-grade TCE degreaser sump, to evaluate the effectiveness of the soil excavation source removal, the presence of potential residual VOCs in soil and soil gas, and the potential risk of soil vapor intrusion to future building occupants. As subsurface investigation and mitigation at the subject property has not been conducted under the oversight of a regulatory agency, AllWest recommends opening a dialogue with the Orange County Health Care Agency or DTSC to discuss the analytical data and mitigation conducted to date. The second REC is associated with the former gasoline UST removed from the subject property in 1989. Verification samples collected from the excavation following removal reportedly did not detect the presence of petroleum hydrocarbons. The UST removal oversight was provided by the Costa Mesa Fire Department and the Orange County Environmental Health Department; however, during this era regulatory closure letters were not typically issued in cases where there was no soil and/or groundwater impact. Based on site analytical data, regulatory oversight, and the 29 years that has elapsed since the UST removal AllWest does not consider the former UST to be a significant environmental concern to the property. The first HREC is associated with the TPHmo impact to shallow soil beneath the former interior eastern Main Building clarifier. The localized occurrence of TPHmo in soils in the vicinity of the interior clarifier was addressed by soil removal. No further action is warranted.

The second HREC is associated with the former facility surface impact with BeO. As beryllium contamination was mitigated by cleanup and demolition activities, and clearance sampling documented compliance with the established BeO clearance level with one exception, no further action related to beryllium mitigation is warranted at the subject property. AllWest recommends the light fixture within the 3161 Main Building suite identified with a beryllium concentration slightly exceeding the clearance level be mitigated. As beryllium decontamination and demolition activities completed at the subject property were conducted without oversight of the Costa Mesa Fire Department or other regulatory agency, certification of hazardous materials closure has not been obtained. AllWest recommends opening a dialogue with the fire department hazardous materials division, or other local regulatory agency, to discuss whether regulatory agency oversight of hazardous materials closure can be provided.

III. ENVIRONMENTAL PROFESSIONAL’S DECLARATION

We declare that, to the best of our professional knowledge and belief, we meet the definition of Environmental Professional as defined in 40 CFR 312.10(b) and ASTM 1527-13. We have the specific qualifications based on education, training, and experience to assess a property of the nature, history, and setting of the subject property. We have developed and performed the all appropriate inquiries in conformance with the standards and practices set forth in 40 CFR Part 312. Preparer's Signature and Title Reviewer's Signature and Title

IV. SCOPE OF WORK AND LIMITATIONS

This Phase I Environmental Site Assessment (ESA) was prepared in accordance with AllWest’s [Date] proposal, with respect to the property located at 3159 – 3169 Red Hill Avenue and 201 – 235 Paularino

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Avenue in Costa Mesa, California. This assessment was performed in general accordance with ASTM 1527-13 and 40 CFR Part 312, except as set forth in the proposal. The work conducted by AllWest is limited to the services agreed to with [Client]. No other services beyond those explicitly stated should be inferred or are implied. The objective of this ESA was to evaluate the subject site for conditions indicative of a release or threatened release of hazardous substances on, at, in, or to the property. AllWest’s professional services were performed using that degree of care and skill ordinarily exercised, under similar circumstances, by reputable environmental consultants practicing in the location of the subject site during our assessment. This warranty is in lieu of all other warranties, expressed or implied. Our professional judgment regarding the potential for environmental impacts is based on limited data and our investigation was not intended to be a definitive investigation of contamination at the site. Unless specifically set forth in our proposal, the scope of work did not include groundwater, soil sampling or other subsurface investigations, a strict compliance audit of the site, or a review of the procedures for hazardous material use, waste storage or handling prior to disposal, or for personnel safety and health training and monitoring procedures, analyzes of radon, formaldehyde, lead paint, asbestos and other hazardous materials or indoor air quality, occupational health and safety or wetlands surveys.

The purpose of conducting a Phase I ESA is to assess the subject site for conditions indicative of releases or threatened releases of hazardous substances on, at, in or to the property resulting from its current, historic and surrounding land use activities. As noted in 40 CFR Part 312, Environmental Assessments are purely qualitative with conclusions drawn from a multitude of sources as evaluated by the environmental professional using professional judgment. Since soil and groundwater data are typically not generated during assessment activities, report conclusions such as “the site is clean” or alternatively “the site is contaminated” cannot be provided. Recognizing the limitations of the Phase I methodology, AllWest assesses the potential for site contamination using a four tier probability scale designated as: Very Low - 1-5 % chance of discovering contamination at the site which would result in regulatory mandated remedial investigation and clean-up;

Low - 10% chance of discovering contamination at the site which would result in regulatory mandated remedial investigation and clean-up; Moderately Low - 20 - 30 % chance of discovering contamination at the site which would result in regulatory mandated remedial investigation and clean-up; or Moderate - greater than 30% chance of discovering contamination at the site which would result in regulatory mandated remedial investigation and clean-up.

As defined above, these terms are used throughout the report. Entities relying on the report should realize that uncertainty of site environmental condition can be further reduced via soil, soil vapor and groundwater sampling. While this option certainly costs additional monies and extends the assessment’s time frame, it also quantitatively documents site conditions which can facilitate future disposition or re-finance activities. Regarding any subsurface investigation, sampling undertaken or subsurface reports reviewed, our opinions are limited to only specific areas and analytes evaluated, and AllWest is not accountable for analyte quantities falling below recognized standard detection limits for the laboratory method utilized. AllWest does not warrant or guarantee the subject property suitable for any particular purpose, or certify the subject site as clean or free on contamination. As with any assessment, it is possible that past or existing contamination remains undiscovered. The professional opinions set forth in this report are based solely upon and limited to AllWest’s visual observations of the site and the immediate site vicinity, and upon AllWest’s interpretations of the readily available historical information, interviews with personnel knowledgeable about the site, and other readily available information. Consequently, this report is complete and accurate only to the extent that cited reports, agency information, and recollections of persons interviewed are complete and accurate. The opinions and recommendations in this report apply to site conditions and features as they existed at time of AllWest’s investigation. They cannot necessarily apply to conditions and features of which AllWest is unaware and has not had the opportunity to evaluate. Future regulatory modifications, agency interpretations, and/or policy changes may also affect the compliance status of the subject property. AllWest has made no attempt to address future financial impacts to the site (e.g., reduced property values) as

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a result of potential subsurface contaminant migration. DATA GAPS: AllWest has made a good faith effort to

obtain information required by 40 CFR Part 312 to formulate a professional opinion. Instances where data gaps occur are detailed within our report with an opinion as to whether the information void is significant impacting our ability to identify conditions indicative of a release or potential release of hazardous substances. In general, if a data gap is identified by AllWest it will be discussed in the report’s conclusion section with a recommendation for additional work as necessary.

This Phase I ESA was prepared for the sole and exclusive use of [Client], the only intended beneficiaries of our work. This report is intended exclusively for the purpose outlined herein and the site location and project indicated and is intended to be used in its entirety. No excerpts may be taken to be representative of the findings of this assessment. The scope of services performed in execution of this investigation may not be appropriate to satisfy other users, and any use or reuse of this document or its findings, conclusions or recommendations presented herein is at the sole risk of the user. This report is not a specification for further work and should not be used to bid out any of the recommendations found within.

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V. ENVIRONMENTAL ISSUES MATRIX

Trico Pacific Center, 3169 Red Hill Avenue, Costa Mesa, CA 92626 AllWest Project xxxxx.20 On-Site Issues Located

Regulatory Compliance

MSDS Hazmat Permits

O&M Program

Repair Within

1/4 Mile Within 1 Mile

Recommended Action

Refer To Section

55-Gallon Drums No

Above Ground Tanks No

Underground Tanks No F.4

Evidence of Material Discharge/Release

No

Transformers (PCBs) No

Hazardous Materials No

Hazardous Wastes No

Asbestos Fireproofing No None; abatement conducted during facility

demolition/decontamination E.2

Asbestos Bulk Insulation No

Asbestos Walls & Ceilings Yes Remove prior to disturbance

Asbestos Floors Presumed Sample prior to

renovation/demolition

Lead Based Paints No E.2

Mold No

Air Quality Issues Potential Indoor air quality assessment

related to VOC impact detected in soil vapor

G.1, G.2

Radon No

Historical Contamination Yes Perform soil/soil vapor/IAQ

assessment in identified areas of remaining concern

G.2

Off-Site Issues Located Regulatory Compliance

MSDS Hazmat Permits

O&M Program

Repair Within

1/4 Mile Within 1 Mile

Recommended Action

Refer To Section

NPL/SEMS Sites No/Yes 0/1 0/1 None H.1/H.4

RCRIS TSDF Sites No

EnviroStor Yes 5 13 None H.9

CPS-SLIC Yes 3 10 w/in ½ mile None H.11

LUST Yes 2 8 w/in ½ mile None H.13

Sensitive Ecological Areas Yes 0 1 None C.3

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VI. ASSESSMENT FINDINGS

A. GENERAL INFORMATION

1. PURPOSE: This ESA was conducted for [Client], which is pursuing permanent loan financing for the property. As the sale of the subject property is not occurring, information on a reduction in property value due to environmental issues was not provided.

2. PROPERTY ADDRESSES: The addresses associated with the subject property are 3159A&B, 3161, 3165A&B, 3163 & 3169A&B Red Hill Avenue and 201, 205, 225 and 235 Paularino Avenue in Costa Mesa, Orange County, California 92626. The site location is shown on the included figures and within the attached Environmental Data Resources, Inc. (EDR

®) report contained in Appendix A.

3. ASSESSOR’S PARCEL NUMBERS: According

to the Orange County Assessor’s Office, the property is comprised of two contiguous parcels identified with Assessor’s Parcel Numbers (APNs) 427-011-03 and 427-011-04.

4. ZONING: The subject property is zoned MP –

Industrial Park.

5. FACILITY/SITE DESCRIPTION: AllWest visited the subject property on [Date], and was accompanied during the reconnaissance by [Name] Access to the interior areas was comprehensive with the exception of Suite 3161 which is still occupied by 3M. Exterior areas and roofs were fully accessed during the site visit. Adjoining properties were observed from public right-of-ways. Located on the west side of the intersection of Paularino and Red Hill Avenues in Costa Mesa, the subject property is developed on two contiguous rectangular parcels comprising 5.366 acres (233,743 square feet). The parcels have approximately 540 feet of street frontage along Paularino Avenue adjoining northeast and 413 feet of street frontage along Red Hill Avenue adjoining southeast. The subject property is developed with two commercial/industrial buildings between 1967 and 1970. The Main Building (3159 – 3169 Red Hill Avenue), also known as the Red Hill Building, is a two-story structure with two mezzanine areas and includes approximately 63,290 square feet.

The Paularino Building (201, 205 and 225 Paularino Avenue), also known as the CIM Building, is a single-story structure including approximately 24,000 square feet. The buildings occupy approximately 60% of the subject property. The remainder includes graded areas for future parking and landscaping.

Site photographs are included with this report. AllWest’s assessment of the facility did not encounter data gaps that diminish our ability to provide an opinion on a release or potential release of hazardous substances at the subject property.

6. CURRENT USE OF PROPERTY BY TENANT(S):

The buildings on the subject property were unoccupied during AllWest’s site visit with the exception of Suite 3161 which is occupied by 3M. Renovation of the subject property was on-going.

7. INTERVIEWS WITH PRESENT PROPERTY OWNER(S): Prior to AllWest’s site inspection we forwarded a questionnaire to the User for the subject property, [Name]. The questionnaire is used to collect information on past uses and ownerships of the property, and to identify potential conditions that may indicate the presence of releases or threatened releases of hazardous substances at the subject property. The questionnaire was completed by [Name] [Date] and is included in Appendix B.

In the questionnaire, [Name] indicated the property owner to be [Name]. [Name] acquired APN 427-011-03 in 1967, at which time the building was constructed. APN 427-011-04 was acquired by [Name] in 1985; the buildings on the parcel were constructed in 1969-1970. [Name] indicated knowledge of the presence of past chemical storage, USTs, clarifiers/separators, air stacks/vents/odors, floor drains/sumps and waste treatment systems. He also was aware of environmental cleanups, environmental permits, industrial discharge, air quality issues and past industrial usage of the property. [Name] indicated no knowledge of environmental cleanup liens or environmentally-related Activity and Use Limitations on the property.

AllWest’s assessment of the site’s current use did not encounter data gaps that diminish our ability to provide an opinion on a release or potential release of hazardous substances at the subject property.

8. HISTORICAL USE OF PROPERTY: Historical documents in the form of Sanborn maps, aerial

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photographs, topographic maps, city directories and building records were reviewed by AllWest to evaluate past land use of the site. AllWest attempted to review historical documents as far back in time as the property contained structures or the property was used for agricultural, residential, commercial, industrial or governmental purposes, and used professional judgment to determine the extent of historical research.

Aerial photographs from the years 1938, 1952, 1963, 1972, 1977, 1985, 1989, 1990, 1994, 20065 2009, 2012 and 2016 were reviewed. USGS topographic maps dated 1902 (Corona, California 30-minute quadrangle), 1896, 1901 and 1942 (Santa Ana, California 15-minute quadrangles) and 1932, 1935, 1948/1949, 1950/1951, 1965, 1972, 1981 and 2012 (Newport Beach and Tustin, California 7.5-minute quadrangles) were reviewed. A summary of city directories, as well as EDR digital archives, dated from 1950 to 2014 was also reviewed. The historical sources were obtained from EDR of Shelton, Connecticut and are provided in Appendix A. Inspection and environmental records available from City of Costa Mesa and Orange County municipal agencies, including the Assessor’s Office, Building Department, Planning Department, Fire Department and Health Care Agency, and other regulatory agencies, were reviewed. A chain-of-title search was not performed for the subject property.

Aerial Photos 1938: The subject property appeared undeveloped or possibly agricultural. 1952: The subject property appeared undeveloped. 1963: There were no significant changes from the 1952 photograph. 1972: The Red Hill, Paularino and Hot Press Buildings were present on the subject property, along with several small outbuildings or other pieces of equipment. 1977: There were no significant changes from the 1972 photograph, with the exception of a narrow strip structure adjoining west of the Red Hill Building. 1985: There were no significant changes from the 1977 photograph, with the exception of what

appeared to be a concrete apron between the Paularino and Red Hill Buildings. 1989: There were no significant changes from the 1985 photograph. 1990: There were no significant changes from the 1989 photograph. 1994: There were no significant changes from the 1990 photograph. 2005: There were no significant changes from the 1994 photograph. 2009: There were no significant changes from the 2005 photograph. 2012: There were no significant changes from the 2009 photograph. 2016: There were no significant changes from the 2012 photograph.

Topographic Maps 1896 - 1902: The subject property was undeveloped with the exception of a road traversing generally northwest to southeast. 1932 - 1965: The subject property remained undeveloped with the road no longer present. 1972 & 1981: The three original buildings were depicted on the subject property. 2012: No development was depicted on the subject property.

City Directories

Several city directories, dated 1970 through 2014, included the subject property addresses. 201 Paularino Avenue 1986: Alrene Co., AF Ewald 1991: Alrene Co. 1995: Trico Realty 2002: TR 1 CO Rents, Trico Realty 2005: Business Pk Ventures, Earic Inc, Fordyce Financial Corp., Grove Street Assoc., Imperial San Jose Mobile Estate, Trico Hst Associates

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2010: Business Pk Ventures, Harrison Holdings Assoc., and a variety of Trico-associated businesses 2014: Harrison Holdings Assoc. and a variety of Trico-associated businesses 205 Paularino Avenue 1966: Carbonic Control Co., Industrial Office Supply Co. 1970: Products of Information Systems 1980: California Sport Wear Co. 1986: Mc Jaf Enterprises Inc. 2002: Sunsout Inc. and a variety of individuals 225 Paularino Avenue 1966: Delta Semiconductors Inc. 1970: Sensitron Inc. 1975: Products of Information Systems 1980: Process Systems Inc. 2002: Vacant (XXXX) 235 Paularino Avenue 1986: Bekins Records Management 2002: Vacant (XXXX) 2010: Business Pk Ventures, Harrison Holdings Assoc., and a variety of Trico-associated businesses 2014: Harrison Holdings Assoc. and a variety of Trico-associated businesses 3159 Red Hill Avenue 1986: Happen Photography, Jon Shamborg & Associates 1991: Physician Sales and Service 1995: Quantum Management Inc., Rising Star Contract Service, Stoneridge Realty 2002: Slater Builders Inc. 3163 Red Hill Avenue

1970: Multi Family Division, Wm Lyon Development Co. 1975: JW Christopher, Inc., Hosiery Club of America Inc., See Star Crest Products of Calif. Inc., Ivy Film Productions, Star Crest Products of Calif. Inc., Timcook Investments Ltd. 1980: tarcr est of California 2002: Vacant (XXXX) 3169 Red Hill Avenue 1970: Uninetics Inc. Division of Dyna Plex Inc., State Medical Construction Co., Century Manufacturing Co., Camdel Inc. 1975: Circuit Assembly Corp. 1986: Schiff Photo Mechanics 1991: Ceradyne Electron Sources, Ceradyne Inc. 2002: Ceradyne Inc.

Municipal Agency Files CMFD: Available hazardous materials and UST file information for the subject property was requested from the Costa Mesa Fire Department (CMFD) through the City of Costa Mesa online portal. No files of environmental concern were on file with the CMFD. CMBD: Available permits issued by the Costa Mesa Building Department (CMBD) were requested through the City of Costa Mesa online portal. A response from the CMBD had not been received at the time this study was completed. OCHCA: Available file information for the subject property at the Orange County Health Care Agency (OCHCA) was requested online. Additionally, OCHCA online hazardous materials and wastes, UST and AST, and cleanup databases were reviewed. The subject property was not included on the OCHCA online databases. No files of environmental concern were on file with the OCHCA. EnviroStor and Geotracker: The California Department of Toxic Substances Control (DTSC) EnviroStor and State Water Resources Control Board (SWRCB) Geotracker databases were reviewed online. The subject property was not included on the Geotracker database.

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Ceradyne was included on the EnviroStor database as an inactive facility for having a tiered-permit. The tiered-permit listing indicates that Ceradyne operated at least one waste treatment unit at the subject property.

Previously-Prepared Documents & User-Provided Information As discussed in following Section A.11, AllWest reviewed numerous previously-prepared documents for the subject property, provided by the User and obtained from AllWest’s archives. Information on the subject property’s history included the following information. The subject property was undeveloped prior to construction of the three existing/former buildings circa 1966 to 1968. The subject property facility was originally occupied by electronics and semiconductor manufacturers, a photographic and printing facility, camera manufacturer, and other commercial/industrial occupants between the time of construction and 1986. Ceradyne reportedly was the sole occupant of the buildings from 1985, utilizing the facility as a secure manufacturing facility for ceramic body armor, helmets, armor plates for vehicles and helicopters, and ceramic medical and dental products. Ceradyne was acquired by 3M in 2012; Ceradyne ceased operations at the facility between 2013 and 2016. Information provided by [Name] (Section A.7) indicated the current property owner, acquired APN 427-011-03 in 1967, at which time the building was constructed. APN 427-011-04 was acquired in 1985; the buildings on the parcel had been constructed in 1969-1970.

Summary of Historical Land Use

AllWest’s land use history review for the subject property indicated the subject property was undeveloped, or possibly agricultural, prior to construction of the three existing/former buildings. Construction of the Main Building was reported in 1967; construction of the Paularino and Hot Press Buildings occurred between 1969 and 1970. The subject property facility was originally occupied by electronics and semiconductor companies, a carbonic control company, a photographic company and other commercial/industrial occupants between the time of construction and 1986. Ceradyne was the sole occupant of the buildings from 1985, utilizing

the facility as a secure manufacturing facility for ceramic body armor, helmets, armor plates for vehicles and helicopters, and ceramic medical and dental products. Ceradyne was acquired by 3M in 2012; Ceradyne ceased operations at the facility between 2013 and 2016. The lack of responses from the regulatory agencies prior to completion of this study is considered a data gap. However, based on the information regarding hazardous materials use and subsurface investigation available through the previously-prepared documents available for AllWest’s review, the data gap is not considered significant, and does diminish our ability to provide an opinion on a release or potential release of hazardous substances at the subject property.

9. CURRENT USE OF THE SURROUNDING PROPERTIES: Surrounding property land use can be characterized as commercial buildings. Neighboring properties to the subject site include the following. North: Paularino Avenue then two commercial office buildings (Spectrum – 200 Paularino; City of Costa Mesa Sanitation – 290 Paularino). South: Four commercial office buildings (200, 250, 260, 270 Baker) West: Commercial office (Club Fix – 185 Paularino) East: Red Hill Avenue then two commercial office buildings (3152 and 3158 Red Hill) Evidence of significant hazardous materials use was not observed at vicinity properties.

10. HISTORICAL USE OF THE SURROUNDING

PROPERTY: AllWest reviewed the previously-referenced aerial photographs, topographic maps and city directories to assess the historical land use in the immediate site area.

Aerial Photos 1938: The vicinity largely appeared undeveloped or possibly agricultural, with a few residences visible along a roadway in the existing location of the Costa Mesa Freeway. 1952: There were no significant changes from the 1938 photograph, with the exception of a drive-in movie theater constructed east of the previously-mentioned roadway.

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1963: There were no significant changes from the 1952 photograph, with the exception of several light-industrial buildings having been constructed adjoining south of the drive-in theater. 1972: Many commercial/light-industrial buildings had been constructed in the vicinity of the subject property, with other parcels in the area remaining undeveloped. A residential tract had been constructed north and west of the drive-in theater and additional light-industrial buildings had been constructed south of the theater. The Costa Mesa Freeway had been constructed west of the subject property. 1977: Additional commercial/light-industrial buildings had been constructed east of the Costa Mesa Freeway, with a few parcels also remaining undeveloped. The drive-in theater no longer was present, with the property developed with multi-family housing. Additional housing and possibly commercial buildings were also present south of the former theater property, replacing the light-industrial buildings previously present. 1985: The majority of the vicinity was developed with the existing structures, with the exception of a few of the commercial/light-industrial buildings in the immediate vicinity of the subject property. 1989: There were no significant changes from the 1985 photograph. 1990: There were no significant changes from the 1989 photograph. 1994: There were no significant changes from the 1990 photograph. 2005: There were no significant changes from the 1994 photograph. 2009: There were no significant changes from the 2005 photograph. 2012: There were no significant changes from the 2009 photograph. 2016: There were no significant changes from the 2012 photograph.

Topographic Maps 1896 - 1902: The vicinity was largely undeveloped, with some wetland areas depicted a short distance north, west and east. The road across the subject property branched off of a road in the existing location of the Costa Mesa Freeway to the west; railroad tracks paralleled the freeway.

1932 & 1935: The vicinity remained largely undeveloped, with a few small structures depicted to the west and a distance southwest. A street was depicted adjoining northeast of the subject property in the location of Paularino Avenue. 1942: There were no significant changes from the previous maps, other than the construction of a school adjoining northwest and the presence of additional structures and a drainage channel to the west. 1948 & 1951/1952: Increased development was depicted primarily a distance southwest and southeast. Orange County Airport was depicted southeast as well. 1965: Red Hill Avenue had been constructed adjoining southeast of the subject property. Additional development had been constructed in the vicinity to the west, southwest, and south, including some structures which appeared commercial or light industrial west of the Costa Mesa Freeway. 1972: Commercial or light-industrial buildings were depicted on properties adjoining northwest, northeast, southwest and southeast, as well as additional similar structures elsewhere in the immediate vicinity. Density of development in the more distant vicinity had increased as well. 1981: The immediate vicinity was densely developed with commercial or light-industrial buildings, with increased development throughout the outer vicinity as well. 2012: The 2012 map depicted only streets, town names and the John Wayne Orange County Airport to the east. No significant surface features of environmental concern were depicted on the most recent topographic map or on historical topographic maps for the subject property’s surrounding area.

City Directories

Previously-referenced city directories were reviewed for vicinity facility listings indicative of potential environmental concern. Listings primarily were for commercial and light-industrial occupants. No indications of the presence of significant hazardous materials use was identified.

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Summary of Historical Adjoining Land Use AllWest’s land use history review for the adjoining and surrounding properties indicated the immediate vicinity was largely undeveloped prior to the late-1960s/early-1970s, although Paularino Avenue had been constructed by the early-1930s and Red Hill Avenue by 1950. Following initial development of the immediate vicinity with commercial/light-industrial buildings by the early-1970s, increased construction with similar facilities occurred through the 1980s. AllWest’s assessment of the site’s current and historical surrounding land use did not encounter data gaps that diminish our ability to provide an opinion on a release or potential release of hazardous substances at the subject property.

11. PREVIOUS REPORTS: Multiple previously-prepared reports and other documents for the subject property were reviewed by AllWest for this ESA, obtained from the User and AllWest’s archives. A list of the documents is presented below; pertinent information from the documents is summarized in the appropriate sections of this report, including Sections A, F and G. Copies of selected documents are provided in Appendix C. Underground Tank Closure, Trico Rents, 235 Paularino Avenue, Costa Mesa, California 92626. Kekimian & Associates, Inc. May 1989 Phase I Environmental Site Assessment, 3M Advanced, 3169 Red Hill Avenue, Costa Mesa, California 92626. Weston. July 2013. Phase II Site Assessment, 3M Ceradyne Advanced Facility, Costa Mesa, CA. Weston Solutions, Inc. (Weston). March 25, 2014. Hazardous Materials Inventory – Hot Press Building, 3M Ceradyne Facility, Costa Mesa, California. Weston. April 18, 2014. Phase II Site Assessment Report Peer Review Summary, 3169 Red Hill Avenue, Costa Mesa, CA. AllWest. July 28, 2014. Beryllium Sampling Report Peer Review Summary, 3169 Red Hill Avenue, Costa Mesa, CA. AllWest. August 12, 2014. Phase II Follow=up Site Assessment, 3M Ceradyne Advanced Facility, Costa Mesa, CA. Weston. March 25, 2015.

Demolition, Decontamination, and Excavation Work Plan, 3M/Ceradyne Costa Mesa Facility. American Integrated Services, Inc. Undated. Excavation, Decontamination, and Demolition Completion Report, 3M Ceradyne Advanced Facility, Costa Mesa, California. Weston.

October 2016. Asbestos, Lead & Hazardous Materials Assessment, 201-225 Paularino Avenue and 3159-3169 Red Hill Avenue, Costa Mesa, CA 92626. AllWest. October 25, 2016. Environmental Documents Peer Review Report, 3169 Red Hill Avenue, Costa Mesa, CA. AllWest. November 21, 2016. Environmental Documents Peer Review Summary, 3169 Red Hill Avenue, Costa Mesa, CA. AllWest. November 21, 2016. Beryllium Remediation Report, 201-225 Paularino Avenue and 3159-3169 Red Hill Avenue, Costa Mesa, CA 92626. AllWest. January 24, 2017. Decontamination and Demolition Completion Report, Former 3M Ceradyne Facility, Costa Mesa, California. Weston. April 2018.

B. PHYSICAL CHARACTERISTICS 1. TOPOGRAPHY: Subject site topography is

generally level, at an elevation of approximately 46 feet above mean sea level. The site vicinity demonstrates a general topographic slope towards the northwest.

2. VEGETATION: Mature trees are planted along

the Paularino and Red Hill Avenue frontages of the subject property. Evidence of stressed vegetation was not observed.

3. SOILS: Soils at the subject property are

classified by the U.S. Department of Agriculture Soil Conservation Service as Myford. The Myford series consists of clayey sandy loam soil with very slow infiltration rates.

Fill material, including wood fragments and gravel, was documented in one boring advanced on the subject property during a 2013 subsurface investigation (Section G.2; Weston 2016). The extent and/or source of the fill material was not documented.

Exposed soil was present on the subject property. Stained or otherwise discolored soil was not observed.

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4. GEOLOGY: Based on a review of the USGS Note 36 California Geomorphic Provinces map, the property is located in the Peninsular Ranges geomorphic province of California. The Peninsular Ranges extend into lower California, including the Los Angeles Basin, and are bound by the Colorado Desert to the east. The province includes a series of mountain ranges separated by northwest trending valleys which lie sub-parallel to faults branching from the San Andreas. Geology of the Peninsular Ranges typically is granitic rock intruding older metamorphic rocks.

5. HYDROLOGY: According to information available

through the State Water Resources Control Board (SWRCB), the subject property is located in the East Coast Plain Hydrologic Subarea (801.11) of the Lower Santa Ana River Hydrologic Unit of the larger Santa Ana River Hydrologic Unit. Ground water sampling conducted on the subject property in 2013 documented shallow ground water at approximately 40 feet beneath ground surface (Weston 2013). Ground water flow direction in the vicinity was obtained from vicinity sites as documented on the SWRCB Geotracker database. Vicinity ground water flow direction was documented to the south/southwest towards the Pacific Ocean. The nearest significant surface water to the subject property is the Santa Ana Channel, located approximately 0.42 mile west. There are no monitoring or water supply wells, aboveground water tanks or water reservoirs at the subject property. There is no documentation that the property currently falls under requirements of the National Pollutant Discharge Elimination System (NPDES) and storm water runoff is currently contained to the subject property during construction activities.

C. NATURAL HAZARDS 1. SEISMICITY: The State of California is

considered seismically active, and earthquakes are an unavoidable geologic hazard in Orange County. Based on available geologic literature, no active fault traces traverse the property. The property is not located within an Alquist-Priolo Special Study Zone for fault rupture hazard. The Newport-Inglewood-Rose Canyon Fault Zone is located approximately 5 miles west of the subject property.

2. RADON: Out-gassing of radon has not been identified as a problem in Orange County. The U.S. EPA has prepared a map to assist national, state and local organizations to target their

resources, and to implement radon-resistant building codes. The map divides the country into three Radon Zones, Zone 1 being those areas with the average predicted indoor radon concentration in residential dwellings exceeding the EPA Action Limit of 4.0 picoCuries per Liter (pCi/L) and Zone 3 being those areas with the average predicted indoor radon concentration in residential dwellings less than 2 pCi/L. It is important to note that the California Department of Health Services (DHS), in its California Statewide Radon Survey of 1990, has found homes with elevated levels of radon in all three zones, and both EPA and DHS recommend property-specific testing in order to determine radon levels at a specific location. However, the DHS Radon Survey does give a valuable indication of the propensity of radon gas accumulation in structures. Review of the DHS Radon Survey places the property in Zone 3, where average predicted radon levels are less than 2.0 pCi/L. Seventy State radon tests were conducted in the site zip code of 92626; radon reportedly exceeded 4 pCi/L in five (7%) of the tests. Federal radon testing at 30 sites in Orange County revealed an average 1

st floor living area radon concentration

of 0.763 pCi/L. None of the Federal test results exceeded 4 pCi/L. Based on the radon zone classification and test data, and light-industrial use of the property, radon is not a significant environmental concern.

3. SENSITIVE ECOLOGICAL AREAS: Sensitive ecological areas include wetlands, rivers or creeks, marsh areas and land dedicated for open space. Sensitive ecological areas include wetlands, rivers or creeks, marsh areas and land dedicated for open space. The U.S. Fish and Wildlife Service National Wetlands Inventory database did not depict designated wetlands on or adjoining the subject property. The nearest designated wetlands were depicted 0.42 mile from the property along Santa Ana Channel.

4. FLOODING: The subject property is included on Federal Emergency Management Agency (FEMA) Flood Insurance Map No. 06059C0286J, dated December 3, 2009. The map depicts the property within flood Zone X (unshaded). FEMA defines Zone X (unshaded) as areas of minimal flood hazard.

5. MASS WASTING: No physical evidence of mass wasting, such as landslides or ground

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subsidence, was observed at the property. No retaining walls were observed.

6. OIL AND GAS WELLS: The California Department of Conservation, Department of Oil, Gas and Geothermal Resources (DOGGR) map shows oil and natural gas production wells located in the State of California. According to the map, no oil or gas wells are located on the subject or adjoining properties. One dry hole is located approximately 450 feet west-northwest of the subject property.

D. SITE CHARACTERISTICS 1. PARKING: As the property is currently under

construction no parking is allowed. 2. ROADWAYS: Paularino Avenue borders the

subject property to the northeast and Red Hill Avenue borders the subject property to the southeast. There are no roadways located on the subject property.

3. FENCES: Temporary chain-link construction

fencing surrounds the property.

4. OUTSIDE STORAGE: There is no outside storage at the subject property.

5. BASEMENTS: There are no basements on the

subject property. 6. EASEMENTS: No known easements are located

on the subject property, except for utilities. 7. WELLS: The OCHCA had not responded to a

request for information on the potential presence of monitoring wells on the subject property at the time this study was completed. Monitoring wells were not observed on the property at the time of the reconnaissance.

No evidence of production, dry, domestic water, irrigation or injection wells was observed or documented.

8. SUMPS: Three below-grade separator/clarifier

systems were formerly present at the Main Building on the subject property, as was a stormwater overflow sump. The separator/ clarifier systems were associated with former tenant Ceradyne’s manufacturing activities. One of the separator/clarifier systems was located at the exterior southwestern corner of the Main Building (3159-3169 Red Hill), the second was located within the eastern portion of the Main Building and a third was located inside the western portion of the Main Building. The

separator/clarifier systems and the stormwater overflow sump reportedly discharged to the sanitary sewer. Previous documentation prepared for the subject property (Section A.11) indicated discharge permits were not required (Weston 2013). Petroleum hydrocarbon-impacted soil was documented beneath the interior eastern Main Building separator/clarifier during studies conducted between 2014 and 2016 (Section G.2). Following excavation of the impacted soil, the former clarifier location was backfilled with sand-cement slurry in 2016. Sampling of the contents of the western interior (Building 3169) clarifier reportedly revealed it to be non-hazardous. The contents of this clarifier were removed during demolition activities in 2017 and 2018; the clarifier was backfilled with soil and capped with concrete to match slab foundation. The exterior separator/clarifier also was cleaned out and removed. Ceradyne also operated an “above-ground sump” in the Main Building, which facilitated collection of fluids generated during use of a TCE degreaser in their manufacturing operations. The unit no longer is present at the subject property; no information on associated removal activities was available. Four process-associated pits were formerly located within the Paularino Building, operated by Ceradyne. The pits reportedly were not utilized in association with hazardous materials and were filled/closed in conjunction with building demolition and decontamination activities in 2016. Finally, one sewage ejector sump was previously located within shower area of the Main Building. The sump was removed during building demolition activities; hazardous materials use was not conducted in association with the ejector sump.

9. CATCH BASINS: Catch basins were not

observed on the subject property.

10. PONDS: No ponds or other bodies of water were observed on the subject property.

11. SEWAGE SYSTEM: The subject property is

connected to the municipal sanitary sewer system operated by the Costa Mesa Sanitary District and Orange County Sanitary District.

12. POTABLE WATER SYSTEM: There are

underground water lines at the property. Potable

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water is supplied by Mesa Water District. The 2018 Water Quality Report was available on-line, and documented compliance of the water provided with all applicable water quality standards.

13. WASTE WATER SYSTEMS: No wastewater treatment systems were observed on the subject property. As discussed in Section D.8, separator/clarifier systems associated with Ceradyne’s previous manufacturing activities and a stormwater overflow sump and sewer ejector sump discharged to the sanitary sewer system. According to the environmental consultant retained by 3M for the remediation/demolition project at the property, sewer discharge permits were not required for discharges from the systems (Weston 2013). Ceradyne also was included on the (WDS) database of the SWRCB in the regulatory agency database report (Section H). The facility type was stated to be industrial, defined as a facility that treats and/or disposes of liquid or semisolid wastes from multiple processes. The facility category was stated to be C, which is defined as a facility with no waste treatment system. As discussed in Section A.8, Ceradyne was included on the EnviroStor database as an inactive facility for having a tiered-permit. The tiered-permit listing indicates that Ceradyne operated at least one waste treatment unit at the subject property. According to information provided by the Costa Mesa Sanitary District, the subject property’s sewer connection is charged as an “industrial building”. The Orange County Sewer District stated that no industrial wastewater discharge permits have been issued for the subject property.

14. STORMWATER DISCHARGE: Current stormwater runoff is retained on the subject property during construction activities Previously, the Ceradyne facility at the subject property was covered under a National Pollutant Discharge Elimination System (NPDES) storm water permit (CS000001) and had a Stormwater Pollution Prevention Plan (SPPP). A storm water overflow sump also was located in the vicinity of the Main Building as discussed in Section D.8. Ceradyne was included on the NPDES and California Integrated Water Quality System (CIWQS) databases in the regulatory agency

database report (Section H) for the industrial storm water NPDES permit (1995 to 2017).

15. POWER DISTRIBUTION SYSTEMS: Electricity

is provided to the property by Southern California Edison; natural gas is provided by Southern California Gas Company.

Four pad-mounted transformers were observed on the subject property. No staining or leaks were observed in association with the transformers. Additionally 6 pole-mounted transformers are located along the southern property boundary. No leaks or staining was observed.

E. HAZARDOUS MATERIALS IN FACILITY AND OPERATIONAL SYSTEMS

1. BUILDING STRUCTURE: The two-story plus

mezzanines Main Building on the subject property is of concrete tilt-up construction on a concrete slab-on-grade foundation. Construction of the Paularino Building is similar. Several out buildings were formerly present along the western wall of the Red Hill Building. These structures were wood framed, slab-on-grade buildings ranging from 50 square feet to 120 square feet in size. They were utilized for storage, emergency generator, bag house, and hazardous materials. The out buildings were razed during the beryllium decontamination phase.

Extensive demolition and renovation of the Main and Paularino Buildings, as well as the surrounding parking lots and other areas, was in progress during this assessment.

2. BUILDING MATERIALS: The exterior finish of the

buildings include painted concrete. The buildings have flat roofs with a multi-ply built-up roofing system.

Interior finishes include wallboard and joint compound in both buildings and lay-in ceiling panels in the Paularino building. Building materials generally were in good condition.

ASBESTOS

AllWest conducted ACM sampling/identification at the subject property for the property owner in 2016. Through inspection, AllWest identified 18 suspect ACMs in the Paularino Building and 28 suspect ACMs in the Main Building.

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Through sampling of the identified suspect ACM, AllWest identified flooring and cove base mastic, first floor joint compound, second floor wall texturing, tan resilient floor tile/mastic and roof penetration mastic as ACM in the Main Building. Wallboard/joint compound, tan resilient floor tile/mastic, off-white resilient floor tile, spray-applied acoustical ceiling, black flooring mastic, exterior stucco and silver paint on the roof of the Paularino Building were identified as ACM as well. Information included in the Weston 2018 decontamination/demolition completion report documented removal of roofing mastic, followed by removal of the asphalt rolled capsheet down to the plywood on all building roofs other than that at 3161 Red Hill Avenue. ACM abatement for the identified interior materials, specified by AllWest, was conducted at that time as well, with visual and air clearance confirmed following completion. Ceradyne was included on the Haznet database in the regulatory agency database report (Section H) for disposal of various quantities of asbestos-containing waste in 1993, 2006, 2014 and 2017. Asbestos abatement has been conducted in the subject property buildings, with the exception of Suite 3161 of the Main Building. ACM remains present in the wallboard and joint compound as well as the wall texturing within this suite. At the time of the reconnaissance for this assessment, AllWest observed the building premises for potential ACM; suspect ACM is present within Suite 3161. Suspect ACM consists of resilient flooring, covebase, and carpet mastic. Materials were observed in good condition.

MOLD As part of this environmental assessment, AllWest visually inspected the building premises for the presence of significant mold growth and evidence of water intrusion including walls, ceilings and utility areas. No visual indications of water intrusion or visual or olfactory signs of mold growth were noted during the site reconnaissance. LEAD BASED PAINT AllWest conducted LBP sampling at the subject property for the property owner in 2016. Four paint chip samples were collected from the Paularino Building and six paint chip samples were collected from the Main Building.

Analyses indicated lead concentrations ranging from <0.010% to 0.54%. Lead-containing paint was identified in the white interior paint and gray and brown exterior paints of the Paularino Building; lead-containing paint was not identified in the Main Building. LBP is considered to be coatings containing greater than 0.5% by weight; based on the analytical data, no LBP was identified during the assessment.

OTHER HAZARDOUS BUILDING MATERIALS/COMPONENTS Also included in AllWest’s 2016 hazardous materials assessment was identification of other hazardous materials identified within the Paularino and Main Buildings. Polychlorinated biphenyl (PCB)-containing light ballasts were not identified during a walkthrough assessment. Two mercury-containing switches were identified in the Paularino Building and five were identified in the Main Building. Some tritium exit signs also were identified.

3. MECHANICAL AND HVAC SYSTEMS: HVAC is provided by roof-mounted, split-system air conditioner/heat pump units.

4. BUILDING EQUIPMENT: No building equipment

was observed.

Previously a baghouse, micro-separator and compressor tank were located behind the Main Building, during operation by Ceradyne. Ceradyne also operated an emergency generator. This equipment was not observed present during the site visit.

5. INDUSTRIAL EQUIPMENT: No industrial equipment is present on the subject property. Previous building tenant Ceradyne operated a variety of industrial equipment on the subject property, not limited to plating lines, degreasers, abrasive blasting equipment, a cyclone, compressors, a furnace, curing oven and direct flame afterburner. As discussed in Section G below, this equipment has been removed and decontamination/demolition activities conducted.

F. TOXIC AND FLAMMABLE MATERIALS, COMPRESSED GASES AND PETROCHEMICALS

1. MANUFACTURE/USE: No manufacturing is

conducted at the subject property, which is currently vacant and undergoing significant demolition/renovation.

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Previous property occupant Ceradyne utilized the facility as a secure manufacturing plant for ceramic body armor, helmets, armor plates for vehicles and helicopters, and ceramic medical and dental products. Prior to occupancy by Ceradyne, the subject property facility originally was occupied by electronics and semiconductor manufacturers, a photographic and printing facility, camera manufacturer, and other commercial/industrial occupants.

2. STORAGE:

Current - Hazardous materials were not observed on the subject property during this study, with the exception of those utilized in building renovation activities. Suite 3161 was not accessed and may contain hazardous materials. Previous – As documented in the 2013 ESA

prepared for the subject property, the primary hazardous materials utilized at the subject property by Ceradyne included less than 800 gallons acetone, methyl ethyl ketone, isopropyl alcohol, propane, and approximately 1,300 gallons of lubricants. Although not specifically identified, the presence of plating and degreasing operations reported at the Ceradyne facility in the ESA also documents use of TCE for degreasing and metal plating solutions, including acids and caustics and cyanide. Hazardous materials reportedly were stored within flammable materials cabinets or other designated storage areas. Plating lines and degreasers were documented within the Main Building. An exterior hazardous materials storage area was documented between the Main and Hot Press Buildings, likely the same location as the hazardous waste storage area discussed in Section F.3. Documentation prepared by Weston and reviewed by AllWest for this study indicated that beryllium was utilized by Ceradyne in their manufacturing processes. As a result, beryllium oxide (BeO) accumulation was documented primarily in the southwestern portion of the Hot Press Building and the former “grinding area and mezzanine” of the Main Building during decontamination/demolition activities. A hazardous materials inventory was prepared for the Hot Press Building by Weston in 2014, prior to demolition of the building. Numerous potential hazardous materials-containing items were documented, including those related to light fixtures, fire extinguishers, batteries, transformers microwaves, E-waste was documented, process-related equipment, and process-related hazardous materials, as well as ACM.

Hazardous materials reportedly were removed from the Ceradyne facility during decontamination/demolition activities in 2016 to 2018. During the 2016 AllWest hazardous materials survey of the Paularino and Red Hill/Main buildings (Section A.11), refrigerant and lubricating oils associated with the HVAC equipment were the only remaining hazardous materials documented (other than those associated with building structure/components).

3. GENERATION & DISPOSAL: Current – Hazardous wastes were not observed on the subject property during this study. Suite 3161 was not accessed and is utilized by 3M for ballistic testing. Previous – Previous property occupant Ceradyne was a large quantity generator of hazardous waste. Hazardous waste streams generated reportedly included waste aerosols, flammable solids, lead-contaminated plates, flammable liquids, chemical labpacks, caustic soda, aluminum nitrate power and alkaline battery universal waste. Previous large-quantity hazardous waste storage areas were reported by Ceradyne personnel to have been secondarily contained (Weston 2013). Hazardous waste disposal was facilitated by Heritage Environmental Services. RCRA non-hazardous waste streams reportedly included oily water, clarifier sludge, mercury lamps, oily debris and filters, “powers and chunks” from graphite plate production, oil, liquid Elasoguard and “e-scrap” universal waste. At least one exterior hazardous waste storage area was documented previously at the subject property, located at the southeastern edge of the parking lot east of the Hot Press Building. The hazardous waste storage structure and concrete pad were removed during demolition/ decontamination activities conducted in 2017 and 2018. Sampling of the concrete rubble for disposal characterization documented the concrete to be California and RCRA non-hazardous. Ceradyne was included more than 700 times on the Haznet database in the regulatory agency database report (Section H) for disposal of small to moderate quantities of multiple waste streams, including metal sludge, oil/water separator sludge, solvents and solvent mixtures, organic and inorganic solids, organic liquids, liquids with nickel, liquids with cyanide, acidic liquids with metals, and waste oil/mixed oil and oil-containing waste, between 1993 and 2016.

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Ceradyne also was included on the RCRA Small Quantity Generator (SQG) database in 2017 and Large Quantity Generator (LQG) database in 1986 to 2016 for generation of numerous waste streams, generally similar to those documented on the Haznet database. Generator notices of violation were documented on multiple occasions between 1990 and 2003 with the RCRA generator listings. The ECHO database listing for Ceradyne indicated the last inspection was in 2013, at which time no violations were documented. As discussed in Section A.8, Ceradyne was also included on the EnviroStor database as an inactive facility for having a tiered-permit. The tiered-permit listing indicates that Ceradyne operated at least one waste treatment unit at the subject property.

4. UNDERGROUND STORAGE TANKS: Based on previously-prepared documents for the subject property (Section A.11), one 1,000-gallon gasoline UST, installed in approximately 1967, was removed from the subject property in 1989. The UST reportedly was located within a drum storage area in the southeastern portion of the 201-235 Paularino Avenue portion of the property. Petroleum hydrocarbons were not detected in two verification soil samples collected following removal of the tank.

The UST removal was conducted under regulatory oversight by the Costa Mesa Fire Department and the Orange County Environmental Health Department. Regulatory closure letters were not typically issued in cases where there was no soil and/or groundwater impact during this time period. Based on site analytical data, regulatory oversight, and the 29 years that has elapsed since the UST removal AllWest does not consider the former UST to be a significant environmental concern to the property The property owner, was included on the UST database in the regulatory agency database report (Section H). No significant information was included in the UST listing.

5. ABOVEGROUND STORAGE TANKS: ASTs were not observed at the subject property. No documentation of the former presence of ASTs was found, however plating lines with presumed open tanks of plating solutions were documented during occupancy of the facility by Ceradyne.

G. POLLUTION SOURCES, CONTROLS AND TREATMENT

1. AIR: Emission permits for the subject property

were requested from the South Coast Air Quality Management District (SCAQMD). A response had not been received at the time this study was completed. Ceradyne was included on the Emissions Inventory (EMI) database of the Air Resources Board (ARB) in the regulatory agency database report (Section H) between 1990 and 2001 for emission of between 10 and 20 tons/year of total organic hydrocarbon gases and reactive organic gases. Emissions between 2008 and 2013 also included up to 10 tons/year (but generally less than 1 ton) of carbon monoxide, nitrogen oxide, sulfur oxide and particulate matter.

Air emission information for previous property occupant Ceradyne was included in the 2013 ESA. According to the report, SCAQMD records available at the time indicated Ceradyne had eight permit applications for two abrasive blasting units, a cyclone, a graphitization and carbonization furnace, an emergency generator, miscellaneous blending activities, a plastic/resin curing oven and a direct-flame afterburner. The permit applications reportedly were under review at the time of the study. Dust collectors also were noted at the property at the time of the 2013 ESA; the dust collectors reportedly were permitted through the SCAQMD as well.

2. SOIL, SOIL VAPOR & GROUNDWATER: Following completion of the 2013 ESA on the subject property, 3M (which had acquired Ceradyne by that time) retained environmental consultant Weston to perform Phase II soil, soil gas and ground water quality investigations at the subject property. The purpose of the studies was to identify whether former manufacturing activities conduced at the Ceradyne facility had impacted the subsurface. Based on the available information, it does not appear that regulatory agency oversight (CMFD or OCHCA) was involved at any point during the investigations or subsequent remedial activities. Information summarized in the following sections was obtained from the previously-prepared reports discussed in Section A.11 and included in Appendix C. Soil - No volatile organic compounds (VOCs), semi-volatile organic compounds (SVOCs), total petroleum hydrocarbons as gasoline (TPHg) or cyanides were detected in the soil samples collected from the vicinity of the exterior separator/clarifier, the interior separator clarifier

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in the eastern portion of the Main Building, former TCE degreaser area and former gold plating line area. Beryllium and lead were detected at low concentrations not exceeding applicable regulatory agency residential screening levels and within naturally occurring background levels for California in the initial samples. Beryllium was not detected in four additional soil samples collected from the parking lot adjoining the Hot Press Building in 2015. Chromium VI and thallium (one location only) concentrations exceeded industrial EPA Regional Screening Levels (RSLs) but not industrial California Human Health Screening Levels (CHHSLs). Thallium reportedly was not used by Ceradyne in its processes. The remainder of the CAM-17 metals were either not detected or detected at concentrations less than the industrial and residential CHHSLs. Since the subject property is zoned as industrial, Weston concluded none of the detected metals were a concern. Total petroleum hydrocarbons in the motor oil range (TPHmo) were detected in the vicinity of the clarifier in eastern portion of the Main Building (sample location HA-01), at concentrations of up to 3,170 milligrams per kilogram (mg/kg). Weston concluded the occurrence of TPHmo was localized based on the lack of detection of petroleum hydrocarbons at other sample locations. During facility decontamination and demolition activities in 2016, Weston conducted soil removal beneath the clarifier in the eastern portion of the Main Building, to mitigate elevated TPHmo concentrations localized in the vicinity of soil boring HA01. The final excavation measured approximately 6 feet by 8 feet and extended to a depth of approximately 5 to 6.5 feet bgs. The precise location and extent of the excavation was not shown on the site plan included in the Weston report. One confirmatory soil sample was collected from the bottom of the excavation; no petroleum hydrocarbons were detected. The excavation was backfilled with cement slurry. In a review of the remediation work conducted by Weston in the vicinity of the eastern Main Building clarifier/separator, AllWest concurred the localized occurrence of TPHmo in soils in the vicinity of the interior clarifier was addressed by soil removal and that no further action was warranted in that vicinity. Soil Gas – Concurrent with the soil quality investigation, soil gas sampling was conducted in the Main Building, including collection of samples

in the vicinity of the exterior and eastern interior clarifier/separators, former TCE degreaser area and former gold plating line area. TCE was detected in five of eight soil gas samples, with TCE concentrations exceeding the CHHSL of 1,800 micrograms per cubic meter (μg/m

3) for shallow soil gas for

commercial/industrial land use in two samples in the southern portion of the former TCE degreaser area (SG-02; 3,100 μg/m

3 and northwestern

portion of the former gold plating line area (SG-04; 7,900 μg/m

3). 1,2-dichloroethane (1,2-DCA)

also was detected in soil gas sample SG-04 at 270 μg/m

3, exceeding the commercial/industrial

CHHSL of 170 μg/m3.

We note VOCs were not detected in soil samples collected from the immediate vicinity of the soil gas sample locations where significant concentrations of TCE and 1,2-DCA were detected. During facility decontamination and demolition activities in 2016, Weston conducted soil removal in the vicinity of the former gold plating line area (SG-04) in the Main Building. The excavation measured approximately 10 feet by 10 feet and extended to a depth of approximately 5 feet bgs. The precise location and extent of the excavation was not shown on the site plan included in the Weston report. One confirmatory soil sample was collected from the bottom of the excavation; no VOCs were detected. Based on previous review of the soil gas sampling data obtained by Weston (Section A.11), AllWest recommend additional sub-slab soil gas sampling in the vicinity of previous probes SG-02 and SG-04 and other locations, as the source of TCE in soil vapor has been identified. AllWest opined shallow soils surrounding the former TCE degreaser and gold plating line areas in the Main Building had not been adequately characterized laterally to identify the potential source area of the TCE in soil vapor. Groundwater - Collection of four ground water

samples from temporary wells was conducted by Weston in 2013. Although the samples all were collected from exterior areas on the Main Building portion of the property, locations included one sample from the up-gradient property boundary, one from the down-gradient property boundary and one nearby down-gradient of the former hazardous waste storage area. No VOCs, beryllium, lead or petroleum hydrocarbons were detected in the groundwater samples collected from the immediate vicinity

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adjoining the exterior of the Main Building. No SVOCs were detected in the groundwater samples, with the exception of di-n-butyl phthalate, which was detected in all of the groundwater samples at concentrations beneath the EPA RSL for tap water. Based on their review of the 2013 ground water monitoring data, AllWest concurred with Weston that groundwater contamination did not appear to be an environmental concern.

3. DECONTAMINATION AND DEMOLITION: In 2016, 3M contractor Weston conducted oversight of American Integrated Services, Inc. (AIS) and during their excavation, decontamination, demolition and confirmation activities and of Clark Seif Clark, Inc. (CSC) in their wipe sampling activities at the subject property. Excavation activities were previously discussed in Section G.2. Decontamination, demolition and confirmation activities conducted under the supervision of Weston included wipe sampling for clearance of equipment and building areas (including BeO sampling), decontamination of equipment in Hot Press Building, decontamination of the former grinding area/mezzanine and demolition of the mezzanine in the Main Building, and decontamination and demolition of the Hot Press Building. No regulatory agency oversight (CMFD) of the decontamination activities appears to have been requested by 3M or Weston. The Main Building mezzanine structure and the entire Hot Press Building structure, floor slab and foundation footings were demolished and removed from the site. Excavated areas were backfilled with imported soil and graded. Demolished building materials and debris were transported to off-site disposal facilities. Additional decontamination and demolition activities were conducted on the subject property by AIS and overseen by Weston in 2017 and 2018, including additional decontamination and demolition of the buildings and associated exterior structures, removal of HVAC units, associated ducting and rooftop appurtenances, removal of BeO dust-impacted asphalt and concrete from the parking lot between the Paularino Building and former Hot Press Building and former hazardous waste storage areas, and asbestos abatement (Section E.2). Following discovery of beryllium in interior and exterior Main Building areas not previously sampled, additional surface cleaning was conducted and items such as insulation, ducting, piping runs, equipment and lighting fixtures were

removed. Wipe sampling conducted both on interior and exterior main building surfaces by CSC and AllWest following the additional decontamination activities documented beryllium clearance levels had been achieved. Roof areas documented as impacted by dust containing beryllium or California hazardous for zinc and nickel also were removed for disposal at the time of the 2017/2018 demolition/decontamination process. In our 2017 Beryllium Remediation Report, AllWest concluded that, based on the project observations and confirmatory wipe sampling data, BeO contamination was successfully remediated from the Paularino Building (Suites 201, 205 and 225) and Main Building (Suites 3159-A&B, 3163, 3165 and 3169-A&B). All of the wipe sample analytical results were below detection limits or the beryllium clearance level of 0.2 μg/100 cm

2. Additionally, all exterior

outbuildings along the western wall of the Main Building, former hazardous waste storage area and parking lot between the Paularino Building and former Hot Press Building were documented by AllWest to have been successfully remediated. Since the Hot Press Building was demolished, confirmatory wipe samples were not collected. At the time of the 2017 Beryllium Remediation Report, AllWest recommended beryllium clearance sampling be conducted within the 3161 Main Building suite, which remained occupied by 3M at the time. Subsequently, sampling was conducted and one light fixture present within the suite demonstrated a beryllium concentration of 0.26 ug/100 cm

2, exceeding the 0.20 ug/100 cm

2

clearance level. The final disposition of the light fixture reportedly remains to be addressed by 3M and the property owner. Following completion of the decontamination and demolition project in 2017 and 2018 Weston concluded, in their April 2018 Decontamination and Demolition Completion Report, that no additional further action was warranted at the subject property.

4. VAPOR INTRUSION: As part of our assessment AllWest evaluated the potential for vapor intrusion into property structures following the general methodology outlined in ASTM E-2600-15, utilizing professional judgment. The Tier 1 screening assessment was employed to determine if a potential vapor intrusion condition (VIC) exists at the site. The subject property, adjoining properties, and hydraulically up-gradient properties were assessed to

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determine known or suspect contaminated sites within approximate minimum search distances. A Tier 1 screening assessment consists of a search distance test to identify if there are any known or suspected contaminated sites within the primary and secondary areas of concern; a chemicals of concern test to determine if chemicals of concern exist at the known or suspected contaminates sites; and a plume test to determine whether or not chemicals of concern in the contaminated plume may be within the critical distance. The critical distance is defined as the linear distance in any direction from the nearest edge of the plume to the site. If the distance from the site to the nearest edge of a petroleum hydrocarbon plume is less than 30 feet or less than 100 feet for non-petroleum chemicals of concern, then it is presumed that a potential vapor intrusion condition (pVIC) exists and additional screening may be necessary.

The potential for a VIC from manufacturing activities previously conducted on the subject property by Ceradyne is assessed as moderately low. TCE and DCE have been detected in soil vapor beneath the former TCE degreaser and gold plating line areas beneath the Main Building. The source of the VOCs in the soil vapor does not appear to have been identified and shallow soil in the areas where impacted soil vapor was detected have not been adequately characterized to identify the potential source area. The potential for a VIC from surrounding land use is considered very low due to the absence of suspect contaminated sites within 30/100 linear feet of the subject property building.

METHANE: The subject property is not located within 1,000 feet of an active landfill, an active oil well or an abandoned/inactive oil well.

5. SOLID WASTE: Solid waste is not currently

generated at the subject property, other than construction debris, as it is unoccupied. Municipal solid waste disposal will be provided to future tenants by Costa Mesa Sanitary District.

6. MEDICAL WASTE: Current or previous

generation of medical waste was not documented on the subject property.

H. REGULATORY DATABASE SEARCH

To identify the site's potential listing in environmental databases and evaluate off-site

environmental concerns, AllWest reviewed a site-specific radius report provided by EDR, which searched regulatory agency lists/ databases for recorded sites within the industry standard search radii. The purpose of the records search was to assess the potential presence of hazardous substance contamination at the subject site as a result of activities conducted on properties within the ASTM-designated search distances. A list of the state and federal regulatory databases searched, summary of findings and detailed records are presented in Appendix A. Regulatory-listed sites and high-risk historical facilities identified by EDR as being within their approximate minimum search distances from the subject property on the ASTM-required databases are listed in Table 1 as well as being summarized in Appendix A and their respective locations identified by number in Appendix A’s figures. The number of sites shown in Table 1 may not exactly reflect what is provided in the EDR report due to multiple (duplicate) listings, outdated (historical databases), and differing minimum search radii as specified in ASTM E 1527-13. Additionally, some map locations shown on the EDR figures refer to more than one site, some sites are listed multiple times in the EDR report and some map locations shown on the EDR figures were determined by AllWest to be incorrect. The EDR report identified one orphan site (sites which addresses are as inadequate or incomplete as to render locating the site on a map ineffective) that could be within the approximate minimum search distances on the ASTM-required databases. Based on the available location information for the site, it doesn’t appear to be located on or adjoining the subject property, or to otherwise be of significant concern. When reviewing the EDR report, AllWest was particularly interested in the regulatory status of sites within the search radius that were adjoining or hydraulically up-gradient to the subject site. In general, only up-gradient hazardous materials release sites represent a potential environmental impact to the subject property. Chemical release sites located hydraulically down-gradient or cross-gradient (perpendicular) are considered unlikely to impact the subject property. Ground water flow direction in the vicinity of the subject property has been documented towards the south/southwest, making sites to the north/northeast up-gradient.

For generation and disposal of manufacturing-related hazardous waste during previous occupancy of the subject property and disposal of

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asbestos-containing waste, former subject property tenant Ceradyne and current property owner were listed on one or more of the following databases. RCRA SQG The EPA’s RCRA Small Quantity

Generators (SQG) list includes facilities that generate between 100 kg and 1,000 kg of hazardous waste per month. The listing is discussed in Section F.3 and in the following discussion.

HAZNET The California Environmental

Protection Agency (DTSC) “Haznet” list includes information on sites which submit hazardous wastes manifests for off-site transportation and disposal of hazardous waste. The wastes disposed are discussed in Sections E.2 and F.3 as well as in the following discussion.

FINDS The Federal EPA's Facility Index

System (FINDS) database contains facility information and "pointers" to other sources that contain more information on the storage and transportation of hazardous materials or waste. No pertinent information was provided.

ECHO The EPA’s Enforcement &

Compliance History Information (ECHO) list is an integrated compliance and enforcement information database for regulated facilities nationwide. No pertinent information was provided.

For the gasoline UST previously located on the subject property, current property owner was listed on the following database. UST The SWRCB’s UST database

includes active UST facilities gathered from local regulatory agency listings. The UST listing is discussed in Section F.4 and in the following discussion.

For air emissions related to manufacturing during previous occupancy of the subject property, former tenant Ceradyne was listed on the following databases. EMI The California Air Resources

Board’s Emissions Inventory Data (EMI) list includes toxics and criteria pollutant emissions data. The site

listing is summarized in Section G.1.

FINDS The Federal EPA's Facility Index

System (FINDS) database contains facility information and "pointers" to other sources that contain more information on the storage and transportation of hazardous materials or waste. No pertinent information was provided.

For permitting related to disposal of industrial wastewater from previous on-site manufacturing activities, former property tenant Ceradyne was listed on the following databases. ENVIROSTOR The DTSC’s Site Mitigation and

Brownfields Reuse Program’s EnviroStor database identifies sites with known contamination as well as sites for which there may be reasons to investigation further. The Tiered Permit listing is discussed in Sections A.8 and D.13 as well as in the following discussion.

WDS The SWRCB’s WDS list includes

sites which have been issued waste discharge requirements. The listing is discussed in Section D.13.

For storm water management under NPDES permitting, former subject property tenant Ceradyne was listed on the following databases. NPDES The SWRCB’s NPDES database is

a listing of facilities with NPDES permits, including storm water. The listing is discussed in Section D.14.

CIWQS The SWRCB’s CIWQS is a

computer system to track information about places of environmental interest, manage permits and other orders and track other actions. The listing is discussed in Section D.14.

A summary of the on- and off-site database listings is included in Table 2.

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Table 1. Regulatory Database Search Summary

Regulatory List Search Radius Number of Listed

Sites within Search Radius

Number of Listed Sites on Subject

Property

NPL 1 mile None None

RESPONSE 1 mile 1 None

RCRIS – CORRACTS 1 mile None None

SEMS ½ mile 1 None

SEMS-ARCHIVE ½ mile 1 None

RCRIS – TSDF ½ mile None None

RCRIS Generators Site & Adjoining 1 1

ERNS Site None None

EnviroStor 1 mile 13 1

Toxic Pits 1 mile None None

CPS-SLIC ½ mile 10 None

State Landfills (SWF/LF) ½ mile None None

LUST ½ mile 8 None

Registered UST/AST Site & Adjoining 1/0 1/0

HAZNET Site 3 3

EDR® Historical

Manufactured Gas Plants 1 mile None None

EDR® Historical Auto Stations

1/8 mile 1 None

EDR® Historical Cleaners 1/8 mile None None

1. U.S. Environmental Protection Agency:

National Priority List (NPL)

The NPL is an U.S. Environmental Protection Agency (USEPA) database listing of the United States’ worst uncontrolled or abandoned hazardous waste sites. NPL sites are targeted for possible long-term remedial action under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) of 1980. In addition, the NPL Report includes information concerning cleanup agreements between the U.S. EPA and Potentially Responsible Parties (commonly called Records of Decision or RODS), any liens filed against contaminated properties, as well as the past and current U.S. EPA budget expenditures tracked

within the Superfund Consolidated Accomplishments Plan (SCAP). The list publication date is December 2017. The search radius for NPL is one-mile. The subject property is not listed on the NPL. There are no NPL sites within one-mile of the subject property.

2. California Department of Toxic Substance

Control: Equivalent National Priority List (RESPONSE)

The RESPONSE database is a California Department of Toxic Substances Control (DTSC) database listing of the State of California’s NPL-equivalent sites. These confirmed release sites

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are generally high-priority and have a high potential risk. They are those where the DTSC is involved in remediation of the site. The list publication date is January 2018. The search radius for RESPONSE is one mile.

The subject property is not listed on RESPONSE. There is one RESPONSE site within one mile of the subject property. Costa Mesa Air National Guard is located approximately 0.91 mile down-gradient of the subject property and therefore unlikely to be of significant concern.

3. U.S. Environmental Protection Agency:

Resource Conservation and Recovery Act Information System (RCRIS) Corrective Action (CORRACTS) Facilities

The RCRIS CORRACTS database contains information pertaining to hazardous waste treatment, storage, and disposal facilities (RCRA TSDFs) which have conducted, or are currently conducting, a corrective action(s) as regulated under the Resource Conservation and Recovery Act (RCRA). The list publication date is December 2017. The search radius for CORRACTS is one mile. The following information is included within the CORRACTS database:

Information pertaining to the status of facilities tracked by the RCRA Administrative Action Tracking System (RAATS);

Inspections & evaluations conducted by Federal and state agencies; all reported facility violations, the environmental statute(s) violated, and any proposed & actual penalties; and

Information pertaining to corrective actions undertaken by the facility or U.S. EPA.

The subject property is not listed on CORRACTS. There are no CORRACTS sites within one mile of the subject property.

4. U.S. Environmental Protection Agency:

Superfund Enterprise Management System (SEMS) – Formerly CERCLIS

The U.S. EPA’s SEMS database is a newly-implemented application that integrates the former CERLIS database, the Superfund Document Management System (SDMS) and a few additional internal EPA applications. The SEMS database is a listing of hazardous waste sites, potentially hazardous waste sites and remedial activities performed in support of the Superfund Program pursuant to Section 103 of the Comprehensive Environmental Response,

Compensation and Liability Act (CERCLA). SEMS sites have either been investigated, or are currently under investigation, by the U.S. EPA for the release or threatened release of hazardous substances. The SEMS list also includes sites which are either proposed for listing or are listed on the NPL, or which are in the screening and assessment phase for possible NPL inclusion. The list publication date is January 2018. The search radius for SEMS is ½ mile. The subject property is not listed on SEMS. There is one SEMS site within ½ mile of the subject property. Western Digital Corp at 3128 Red Hill Avenue, approximately 0.13 mile generally down-gradient, had a release of VOCs to ground water. Based on information included on the Geotracker database, the facility has a status of Completed-Case Closed. Based on the down-gradient location and regulatory status, it is unlikely to be of significant concern to the subject property.

5. U.S. Environmental Protection Agency: SEMS-Archive – Formerly CERCLIS NFRAP

The U.S. ESA has replaced the CERCLIS No Further Remedial Action Planned (NFRAP) database with the SEMS-Archive database. SEMS-Archive tracks sites that have no further interest to the EPA under the Superfund Program based on available information. Listing on the Archive database indicates that to the best of EPAs’ knowledge, no further steps will be taken to list the site on the NPL. The U.S. EPA may perform a minimal level of assessment at a SEMS-Archive site if new information becomes available, however. Listing on the SEMS-Archive database does not necessarily indicate there is no hazard associated with the site, only that the site is not judged to be a potential NPL site. The list publication date is January 2018. The search radius for SEMS-Archive is ½ mile.

The subject property is not listed on SEMS-Archive. There is one SEMS-ARCHIVE site within ½ mile of the subject property, MSI Data Corp. at 335 Baker Avenue, approximately 0.16 mile cross- to down-gradient. Significant information on the site was not included in the database report. Based on the down-gradient location and ARCHIVE status, it is unlikely to be of significant concern to the subject property.

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6. U.S. Environmental Protection Agency: Resource Conservation and Recovery Act Information System (RCRA) Treatment, Storage, and Disposal Facilities (TSDF)

The RCRA-TSDF is a U.S. EPA listing of facilities that were permitted under RCRA to perform on-site treatment, storage, or disposal of hazardous wastes. The sites listed in RCRA-TSDF do not necessarily pose an environmental threat to the surrounding properties because the TSDF permit imposes stringent monitoring and reporting requirements. The list publication date is December 2017. The search radius for RCRA-TSDF is ½ mile. The following information is also included in the RCRA TSDF database:

Information pertaining to the status of facilities tracked by the RCRA Administrative Action Tracking System (RAATS);

Inspections & evaluations conducted by federal and state agencies; and

All reported facility violations, the environmental statute(s) violated, and any proposed & actual penalties.

The subject property is not listed as a RCRA-TSDF facility. There are no RCRA-TSDF sites located within ½ mile of the subject property.

7. U.S. Environmental Protection Agency: Resource Conservation and Recovery Act Information System (RCRIS) Generators List

The RCRA generators list is a US EPA listing of facilities that generate hazardous wastes or meet other applicable waste generating requirements under RCRA. The sites listed in the RCRA Generator List have not necessarily released hazardous waste into the environment and may not necessarily pose an environmental threat to the surrounding properties. These listed sites are required to properly contain the wastes generated and remove their wastes from the site within 90 days. Furthermore, the facilities that report waste generation activities are more inclined to perform the required monitoring. The list publication date is December 2017. The search radius for the RCRIS Generator List is the Site and adjoining properties. The subject property was included on the RCRIS Generator List, both as a SQG and a LQG for previous occupant Ceradyne. Ceradyne was included on the RCRIS Generator Lists from 1986 to 2017 for generation of numerous waste streams. Generator notices of violation were documented on multiple occasions between 1990

and 2003. The listings are further discussed in Section F.3. There were no adjoining properties included on the RCRIS Generators database.

8. U.S. Environmental Protection Agency:

Emergency Response Notification System (ERNS) List

The Emergency Response Notification System (ERNS) list is a U.S. EPA maintained list of reported incidents that concern the sudden and/or accidental release of hazardous substances, including petroleum, into the environment. The list publication date is January 2018. The search radius for ERNS is the subject property. The subject site is not listed on the ERNS list.

9. California Department of Toxic Substances

Control (DTSC): EnviroStor Sites

The EnviroStor database is a DTSC listing of sites under investigation that could be actually or potentially contaminated and that may present a possible threat to human health and the environment. The list publication date is January 2018. The search radius for EnviroStor is one mile. The subject property, as Ceradyne, is included on the EnviroStor database in the Tiered Permit program. Inclusion in the Tiered Permit program indicates the former presence of a waste treatment system at the facility. The facility status was Inactive-Needs Evaluation. The EnviroStor listing is discussed in Sections A.8 and D.13.

There are 12 EnviroStor sites located within one mile of the subject property, with none on adjoining properties. Three EnviroStor sites were documented within 1/3 mile of the subject property. Semicoa at 333 McCormick, approximately 0.15 mile cross-gradient, was listed twice on the EnviroStor database for being in the Tiered Permit program. As the site was not included on other databases indicative of a release, the EnviroStor listing is not of significant concern. Frye & Smith Inc. at 150 E. Baker Street, approximately 0.11 mile down-gradient, had a status of No Further Action in the Tiered Permit program. Based on the down-gradient location and No Further Action status, it is unlikely to be of significant concern to the subject property.

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Prime Technologies at 3183 Red Hill Avenue, approximately 0.18 mile cross- to up-gradient, had a status of Inactive-Needs Evaluation in the Tiered Permit program. As the site was not included on other databases indicative of a release, the EnviroStor listing is not of significant concern. Based on the distance and direction of the other listed facilities from the subject property, they also are unlikely to be of significant concern.

10. California Department of Toxic Substances Control: Toxic Pits Cleanup Act Sites (Toxic Pits)

The TPCA is a California Department of Toxic Substances Control (DTSC) listing of hazardous waste cleanup sites regulated pursuant to the California Toxic Pits Cleanup Act (Toxic Pits). The list publication date is July 1995. The search radius for TPCA is one mile.

The subject property is not listed on TPCA Sites list. There are no Toxic Pits sites within one mile of the subject property.

11. California Regional Water Quality Control Board: Cleanup Program Sites (CPS)-Spills, Leaks, Investigations and Cleanup (SLIC)

The CPS-SLIC is a California Regional Water Quality Control Board (RWQCB) listing of sites that have reported spills, leaks, investigative activities and/or cleanup actions. The list publication date is March 2018. The search radius for CPS-SLIC is ½ mile. The subject property is not listed on the CPS-SLIC database. There are 10 CPS-SLIC sites within ½ mile of the subject property, but none on adjoining properties and none within 1/3 mile up-gradient. Two SLIC sites were reported in generally up-gradient locations, ITT Business Machine at 3191 Red Hill Avenue and Valentec at 3190 Pullman Street, but both had a regulatory status of Completed-Case Closed and therefore are unlikely to be of significant concern. Based on the distance and location of the other SLIC sites from the subject property, they also are not anticipated to be of significant concern.

12. California Integrated Waste Management Board: Solid Waste Information System (SWF/LF) Facilities

The SWF/LF is a California Integrated Waste Management Board (CIWMB) listing of all permitted active, inactive, or closed landfills. The

list publication date is February 2018. The search radius for SWF/LF is ½ mile. The subject property is not listed on SWF/LF list. There are no SWF/LF sites within ½ mile of the subject property.

13. California Regional Water Quality Control Board: Leaking Underground Storage Tanks (LUST)

The LUST list is an Ecology listing of sites that have reported leaking underground storage tanks. A site may be listed on LUST by reporting the tank system(s) failed tank testing, that routine monitoring of tank system(s) showed evidence of leakage, or that verification sampling during tank removal showed subsurface contamination. The list publication date is March 2018. The search radius for the LUST list is ½ mile. Fuel leak case research conducted at the Lawrence Livermore National Laboratory (LLNL) indicates that attenuation and degradation play major roles in reducing hydrocarbon in groundwater to non-detectable levels within several hundred feet of the contaminant source. Research findings indicate that in over 90% of the petroleum hydrocarbon cases, groundwater contaminant plumes do not extend more than 250 feet from the source. The mobility of a gasoline additive called Methyl tertiary-Butyl Ether (MtBE) is currently being researched. Preliminary findings indicate that MtBE is highly soluble in water and moves easily through soil particles and into groundwater where it may spread over a distance greater than 250 feet. MtBE will transfer to groundwater from gasoline leaking from USTs, pipelines, car emissions into the atmosphere, and other components of gasoline vapor distribution. MtBE has been an additive to gasoline since approximately 1985, but banned in California since 2004. The subject property is not included on the LUST list. There are eight listings for LUST sites within ½ mile of the subject property, with none on adjoining properties and those within ¼ mile all located in cross- to down-gradient locations. Additionally, all the LUST sites within ¼ mile and all up-gradient LUST sites had a regulatory status of Case Closed. Based on the location and regulatory status of the listed LUST sites, they are discounted as being of significant concern.

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14. California Water Resources Control Board: Registered Underground Storage Tank (RUST) and Aboveground Storage Tank (RAST) Lists

The California Water Resources Control Board Underground Storage Tank Program maintains a list of registered underground storage tanks (RUSTs) and registered aboveground storage tanks (RASTs) in the site area. The RUST list publication date is March 2018 and the RAST list publication date is July 2016. The sites listed on the RAST and RUST lists have not necessarily released hazardous substances into the environment and may not necessarily pose an environmental threat to the surrounding properties. Since Federal and California UST regulations require periodic monitoring for UST leakage and the immediate reporting of evidence of UST leakage, only those sites listed on the leaking underground storage tank (LUST) list typically have the potential of environmental impact. The search radius for the RUST and RAST lists is the site and adjoining properties.

The subject property, under property owner [Name], is listed on the RUST list but is not included on the RAST list. The RUST listing is related to a UST removed from the subject property as discussed in Section F.4. No impact to underlying soil was documented following removal of the tank and therefore the listing is not of concern to the subject property. There are no RUST or RAST listings for adjoining sites.

15. California Department of Toxic Substances Control: Hazardous Waste Information System (HAZNET) List

The data on the HAZNET list is extracted from the copies of hazardous waste manifests received each year by the DTSC. The annual volume of manifests is typically 700,000 - 1,000,000 annually, representing approximately 350,000 - 500,000 shipments. Data are from the manifests are submitted without correction, and therefore many contain some invalid values for data elements such as generator ID, TSD ID, waste category, and disposal method. The list publication date is December 2016. The search radius for HAZNET is the site.

The subject property is listed three times on the HAZNET database for disposal of manufacturing-related hazardous wastes and asbestos waste by former property tenant Ceradyne. Ceradyne had documented disposal of small to moderate quantities of multiple waste streams,

including metal sludge, oil/water separator sludge, solvents and solvent mixtures, organic and inorganic solids, organic liquids, liquids with nickel, liquids with cyanide, acidic liquids with metals, and waste oil/mixed oil and oil-containing waste, between 1993 and 2016. Ceradyne also had documented disposal of various quantities of asbestos-containing waste in 1993, 2006, 2014 and 2017. As listing on the Haznet database is indicative of appropriate hazardous waste disposal practices, these listings are not of concern to the environmental condition of the subject property.

16. EDR

® Historical Manufactured Gas Plants

EDR maintains a proprietary list of coal gas plants (manufactured gas plants) derived from city directories, telephone directories and other historical sources. The subject property is not listed as an historical manufactured gas plant. There are no historical manufactured gas plants reported within ¼ mile of the subject property.

17. EDR® Historical Auto Stations

EDR maintains a proprietary list of possible historical automotive repair shops and gasoline stations derived from city directories, telephone directories and other historical sources.

The subject property is not listed as an historical auto station.

There is one historical auto station reported within 1/8 mile of the subject property. Beacon Bay Enterprises at 3152 Red Hill Avenue, Suite 230, approximately 0.04 mile down- to cross-gradient was listed as a gas station in 1998 to 2002. The listed location appears to be an office complex and the listing likely therefore is for a business office rather than a service station. The listing is not considered to be of significant concern to the subject property.

18. EDR® Historical Cleaners

EDR maintains a proprietary list of possible historical dry cleaner businesses derived from city directories, telephone directories and other historical sources.

The subject property is not listed on the EDR historical cleaners database. There are no historical cleaners within 1/8 mile of the subject property.

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Summary EDR’s agency database search identified hazardous waste generation, wastewater treatment and discharge to the sanitary sewer, air emissions, and stormwater discharge monitoring by former property occupant Ceradyne. The presence of the former UST also was indicated. As listing on these regulatory agency databases generally is indicative of appropriate waste disposal practices, the listings alone are not indicative of concern to the environmental condition of the subject property. However, the listings do document hazardous materials use and hazardous waste generation at the Ceradyne facility, which has been documented through other means resulting in impact to the subject property. The agency database search found no surrounding or adjoining sites that appear likely to have significantly impacted the soil or groundwater underlying the subject property. AllWest’s search for recorded environmental clean-up liens and reviews of federal, tribal, state and local government records did/did not encounter data gaps that diminish our ability to provide an opinion on a release or potential release of hazardous substances at the subject property.

VII. INFORMATION SOURCES

A. HISTORICAL SOURCES

Aerial Photographs

EDR® Aerial Photo Decade Package, June 22,

2018, Environmental Data Resources, Inc., Shelton, Connecticut. Aerial photographs of 1”=500’ scale dated 1936, 1944, 1953, 1956, 1965, 1969, 1977, 1980, 1985, 1990, 2006, 2011 and 2015 were reviewed.

City Directories

EDR® City Directory Abstract, June 22, 2018,

Environmental Data Resources, Inc., Shelton, Connecticut. City directories dated 1920 through 2014 were available.

Topographic Maps EDR

® Historical Topographic Map Report, June

7, 2018, Environmental Data Resources, Inc., Shelton, Connecticut. Maps dated 1902 (Corona, California 30-minute quadrangle), 1896, 1901

and 1942 (Santa Ana, California 15-minute quadrangles) and 1932, 1935, 1948/1949, 1950/1951, 1965, 1972, 1981 and 2012 (Newport Beach and Tustin, California 7.5-minute quadrangles) were reviewed.

B. AGENCY DATABASES

The EDR® Radius Map Report, June 7, 2018,

Environmental Data Resources, Inc., Shelton, Connecticut. State Water Resources Control Board (SWRCB) GeoTracker database website: http://geotracker.waterboards.ca.gov/ Department of Toxic Substances Control (DTSC) EnviroStor database website: http://www.envirostor.dtsc.ca.gov/public/

C. ENVIRONMENTAL STUDIES

Alquist-Priolo Special Studies Zones Act, Special Publication No. 42, 1997, California Division of Mines and Geology. California Statewide Radon Survey, 1990, California Department of Health Services. California Department of Conservation, California Department of Conservation, Division of Oil, Gas and Geothermal Resources Well Finder, 2016: http://www.conservation.ca.gov/dog/Pages/WellFinder.aspx US Fish and Wildlife Service National Wetlands Inventory database. http://www.fws.gov/wetlands/Data/Mapper.html

D. ZONING, BUILDING AND ASSESSOR Costa Mesa Building Division, 77 Fair Drive, Costa Mesa, CA 92626. Contact: 714-754-5273. http://www.costamesaca.gov/city-hall/city-departments/city-clerk/make-a-public-records-request Costa Mesa Building Division, 77 Fair Drive, Costa Mesa, CA 92626. Contact: 714-754-5270. www.costamesaca.gov/index.aspx?page=1412 Orange County Assessor’s Office, 11 Civic Center Plaza, Santa Ana, CA 92701. Contact: 714-834-2727

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E. FIRE AND ENVIRONMENTAL HEALTH Costa Mesa Fire Department, 800 Baker Street, Costa Mesa, CA 92626. Contact: 714-754-5106. http://www.costamesaca.gov/city-hall/city-departments/city-clerk/make-a-public-records-request Orange County Health Care Agency, 1241 E. Dyer Road, Suite 120, Santa Ana, CA 92705. Contact: 714-433-6000. http://www.ochealthinfo.com/eh/home/reports

F. AIR QUALITY

South Coast Air Quality Management District, 21865 Copley Drive, Diamond Bar, CA 91765. Contact: 909-396-2000.

G. OTHER DOCUMENTS

Underground Tank Closure, Trico Rents, 235 Paularino Avenue, Costa Mesa, California 92626. Kekimian & Associates, Inc. May 1989 Phase I Environmental Site Assessment, 3M Advanced, 3169 Red Hill Avenue, Costa Mesa, California 92626. Weston. July 2013. Phase II Site Assessment, 3M Ceradyne Advanced Facility, Costa Mesa, CA. Weston Solutions, Inc. (Weston). March 25, 2014. Hazardous Materials Inventory – Hot Press Building, 3M Ceradyne Facility, Costa Mesa, California. Weston. April 18, 2014. Phase II Site Assessment Report Peer Review Summary, 3169 Red Hill Avenue, Costa Mesa, CA. AllWest. July 28, 2014.

Beryllium Sampling Report Peer Review Summary, 3169 Red Hill Avenue, Costa Mesa, CA. AllWest. August 12, 2014.

Phase II Follow=up Site Assessment, 3M Ceradyne Advanced Facility, Costa Mesa, CA. Weston. March 25, 2015. Demolition, Decontamination, and Excavation Work Plan, 3M/Ceradyne Costa Mesa Facility. American Integrated Services, Inc. Undated. Excavation, Decontamination, and Demolition Completion Report, 3M Ceradyne Advanced Facility, Costa Mesa, California. Weston.

October 2016. Asbestos, Lead & Hazardous Materials Assessment, 201-225 Paularino Avenue and 3159-3169 Red Hill Avenue, Costa Mesa, CA 92626. AllWest. October 25, 2016. Environmental Documents Peer Review Report, 3169 Red Hill Avenue, Costa Mesa, CA. AllWest. November 21, 2016. Environmental Documents Peer Review Summary, 3169 Red Hill Avenue, Costa Mesa, CA. AllWest. November 21, 2016. Beryllium Remediation Report, 201-225 Paularino Avenue and 3159-3169 Red Hill Avenue, Costa Mesa, CA 92626. AllWest. January 24, 2017. Decontamination and Demolition Completion Report, Former 3M Ceradyne Facility, Costa Mesa, California. Weston. April 2018.

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Description of Selected General Terms and Acronyms

Term/Acronym Description ACM Asbestos Containing Material. Asbestos is a naturally occurring mineral, three varieties of which

(chrysotile, amosite, crocidolite) have been commonly used as fireproofing or binding agents in construction materials. Exposure to asbestos, as well as ACM, has been documented to cause lung diseases including asbestosis (scarring of the lung), lung cancer and mesothelioma (a cancer of the lung lining).Regulatory agencies have generally defined ACM as a material containing greater that one (1) percent asbestos, however some states (e.g. CA) define ACM as materials having 0.1% asbestos.

AHERA Asbestos Hazard Emergency Response Act AOC Area of Concern APN Assessor's Parcel Number AST Aboveground Storage Tanks. ASTs are generally described as storage tanks less than 10% of

which are below ground (i.e., buried). Tanks located in a basement, but not buried, are also considered ASTs. Whether, and the extent to which, an AST is regulated, is determined on a case-by-case basis and depends upon tank size, its contents and the jurisdiction of its location.

ASTM American Society for Testing and Materials AULs Liens or Activity and Use Limitations BAAQMD Bay Area Air Quality Management District bgs Below Ground Surface BTEX Benzene, Toluene, Ethylbenzene, and Xylenes. BTEX are VOC components found in gasoline

and commonly used as analytical indicators of a petroleum hydrocarbon release. BTU/hr British Thermal Units per hour Cal/EPA California Environmental Protection Agency, also known as DTSC CD Critical Distance CFR Code of Federal Regulations COC Contaminant of Concern CREC Controlled Recognized Environmental Condition is defined in ASTM E1527-13 as “a recognized

environmental condition resulting from a past release of hazardous substances or petroleum products that has been addressed to the satisfaction of the applicable regulatory authority (for example, as evidenced by the issuance of a no further action letter or equivalent, or meeting risk-based criteria established by regulatory authority) , with hazardous substances or petroleum products allowed to remain in place subject to the implementation of required controls (for example, property use restrictions, activity and use limitations, institutional controls, or engineering controls).

Data Gap / Significant Data Gap

A lack of or inability to obtain information required by the practice despite good faith efforts by the environmental professional to gather such information. A data gap is significant if other information and/or professional experience raises concerns involving the data gap.

De minimis Condition

A condition that generally does not present a threat to human health or the environment and that generally would not be the subject of an enforcement action if brought to the attention of appropriate governmental agencies.

DOGGR California Department of Conservation, Department of Oil, Gas and Geothermal Resources DTSC California Department of Toxic Substances Control EDR Environmental Data Resources EMI Emissions Inventory Data EPA U.S. Environmental Protection Agency ESA Environmental Site Assessment ESL Environmental Screening Level FEMA Federal Emergency Management Agency HAZNET DTSC Hazardous Waste Information System Hazardous Substance

As defined under CERCLA, this is (A) any substance designated pursuant to section 1321(b)(2)(A) of Title 33, (B) any element, compound, mixture, solution, or substance designated pursuant to section 9602 of this title; (C) any hazardous waste having characteristics identified under or listed pursuant to section 3001 of the Solid Waste Disposal Act (with some exclusions); (D) any toxic pollutant listed under section 1317(a) of Title 33; (E) any hazardous air pollutant listed under section 112 of the Clean Air Act; and (F) any imminently hazardous chemical substance or mixture with respect to which the EPA Administrator has taken action under section 2606 of Title 15. This term does not include petroleum, including crude oil or any fraction thereof

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which is not otherwise listed as a hazardous substance under subparagraphs (A) through (F) above, and the term include natural gas, or synthetic gas usable for fuel (or mixtures of natural gas and such synthetic gas).

Hazardous Waste

This is defined as having characteristics identified or listed under section 3001 of the Solid Waste Disposal Act (with some exceptions). RCRA, as amended by the Solid Waste Disposal Act of 1980, defines this term as a “solid waste, or combination of solid wastes, which because of its quantity, concentration, or physical, chemical, or infectious characteristics may (A) cause, or significantly contribute to an increase in mortality or an increase in serious irreversible, or incapacitating reversible illness; or (B) pose a substantial present or potential hazard to human health or the environment when improperly treated, stored, transported, or disposed of, or otherwise managed.”

HMBP Hazardous Materials Business Plan HMMP Hazardous Materials Management Plan HREC Historical Recognized Environmental Condition is defined in ASTM E1527-13 as “a past release

of any hazardous substances or petroleum products that has occurred in connection with the property and has been addressed to the satisfaction of the applicable regulatory authority or meeting unrestricted residential use criteria established by a regulatory authority, without subjecting the property to any required controls (for example, property use restrictions, activity and use limitations, institutional controls, or engineering controls).

HVAC Heating, Ventilation and Air Conditioning LNAPL Light Non-Aqueous Phase Liquid LOP Local Oversight Program LQG Large Quantity Generators LUST Leaking Underground Storage Tank. This is a federal term set forth under RCRA for leaking

USTs. Some states also utilize this term. mg/kg milligrams per kilogram mg/L milligrams per liter MCL Maximum Contaminant Level. This Safe Drinking Water concept (and also used by many states

as a ground water cleanup criteria) refers to the limit on drinking water contamination that determines whether a supplier can deliver water from a specific source without treatment.

MSDS Material Safety Data Sheets. Written/printed forms prepared by chemical manufacturers, importers and employers which identify the physical and chemical traits of hazardous chemicals under OSHA’s Hazard Communication Standard.

MSL Mean Sea Level MtBE Methyl tertiary Butyl Ether

ND Not Detected NE Not Established NESHAP National Emissions Standard for Hazardous Air Pollutants (Federal Clean Air Act). This part of the

Clean Air Act regulates emissions of hazardous air pollutants. NFA No Further Action NPDES National Pollutant Discharge Elimination System (Clean Water Act). The federal permit system

for discharges of polluted water. NV No Value O&M Plan Operations and Maintenance Plan OSHA Occupational Safety and Health Administration or Occupational Safety and Health Act PACM Presumed Asbestos-Containing Material. A material that is suspected of containing or presumed

to contain asbestos but which has not been analyzed to confirm the presence or absence of asbestos.

PCBs Polychlorinated Biphenyls. A halogenated organic compound commonly in the form of a viscous liquid or resin, a flowing yellow oil, or a waxy solid. This compound was historically used as dielectric fluid in electrical equipment (such as electrical transformers and capacitors, electrical ballasts, hydraulic and heat transfer fluids), and for numerous heat and fire sensitive applications.

pCi/L picoCuries per Liter of air. Unit of measurement for radon and similar radioactive materials. PE Professional Engineer PG&E Pacific Gas and Electric Company PLM Polarized Light Microscopy (see ACM section of the report, if included in the scope of services) ppb parts per billion ppm parts per million

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pVIC Potential Vapor Intrusion Condition Radon

A radioactive gas resulting from radioactive decay of naturally-occurring radioactive materials in rocks and soils containing uranium, granite, shale, phosphate, and pitchblende. Exposure to elevated levels of radon creates a risk of lung cancer; this risk generally increases as the level of radon and the duration of exposure increases. Radon can accumulate in building basements or similar enclosed spaces to levels that can pose a risk to human health. Indoor radon concentrations depend primarily upon the building's construction, design and the concentration of radon in the underlying soil and ground water.

REC

Recognized Environmental Conditions are defined by ASTM E1527-13 as “the presence or likely presence of any hazardous substances or petroleum products in, on, or at a property: 1) due to any release to the environment; 2) under conditions indicative of a release to the environment. De minimis conditions are not recognized environmental conditions.”

RWQCB California Regional Water Quality Control Board SLIC Spills, Leaks, Investigations And Cleanup SPCC Spill Prevention, Control and Countermeasures. SPCC plans are required under federal law

(Clean Water Act and Oil Pollution Act) for any facility storing petroleum in tanks and/or containers of 55-gallons or more that when taken in aggregate exceed 1,320 gallons. SPCC plans are also required for facilities with underground petroleum storage tanks with capacities of over 42,000 gallons. Many states have similar spill prevention programs, which may have additional requirements.

SQG Small Quantity Generator SWRCB State Water Resources Control Board TPH (d)(g)(mo) Total Petroleum Hydrocarbons (d) as diesel (g) as gasoline (mo) as motor oil ug/kg micrograms per kilogram ug/L micrograms per liter USGS United States Geological Survey UST

Underground Storage Tank. Most federal and state regulations, as well as ASTM E1527-13, define this as any tank, incl. underground piping connected to the tank, that is or has been used to contain hazardous substances or petroleum products and the volume of which is 10% or more beneath the surface of the ground (i.e., buried).

VEC Vapor Encroachment Condition VOCs Volatile Organic Compounds Wetlands

Areas that are typically saturated with surface or ground water that creates an environment supportive of wetland vegetation (i.e., swamps, marshes, bogs).

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FIGURES

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PROJECT NO.xxxxx.60.80

REGIONAL MAPFIGURE 1201-225 PAULARINO & 3159-3169 RED HILL COSTA MESA, CA 92626SOURCE: DELORME TOPOPREPARED BY: D. CAMACHO DATE: x/xx/xx

San Francisco

Sacramento

San Jose

Los Angeles

Costa Mesa

San Diego

Costa Mesa

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PROJECT NO.xxxxx.20.80

VICINITY MAPFIGURE 2201-225 PAULARINO & 3159-3169 RED HILL COSTA MESA, CA 92626 SOURCE: DELORME TOPOPREPARED BY: D. CAMACHO DATE: x/xx/xx

SUBJECT PROPERTY

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PROJECT NO.xxxxx.20.80

AERIAL PHOTOFIGURE 3201-225 PAULARINO & 3159-3169 RED HILLCOSTA MESA, CA 92626SOURCE: GOOGLE EARTHPREPARED BY: D. CAMACHODATE: x/xx/xx

201-225 Paularino

Previously demolishedbuilding 3159-3169 Red Hill

Original building line

Re-entrant corners

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PROJECT NO.xxxxx.20.80

SITE PLANFIGURE 4201-225 PAULARINO & 3159-3169 RED HILLCOSTA MESA, CA 92626SOURCE: GOOGLE EARTHPREPARED BY: D. CAMACHODATE: x/xx/xx

201-225 Paularino

3159-3169 Red HillMain Bldg

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PHOTOGRAPHS

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AllWest Project xxxxx.20 Trico Pacific Center – 3169 Red Hill Avenue, Costa Mesa, California

1. Eastern Façade of Red Hill Building Looking Northwest 2. Northern Façade of Red Hill Building Looking Southwest

3. Western Façade of Red Hill Building Looking South 4. Southern Façade of Red Hill Building Looking West

5. Southern Façade of Paularino Building Looking West 6. Eastern Façade of Paularino Building Looking North

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AllWest Project xxxxx.20 Trico Pacific Center – 3169 Red Hill Avenue, Costa Mesa, California

7. Western Façade of Paularino Building Looking South 8. Eastern Façade of Paularino Building Looking Easterly

9. Location of Former Sewer Ejector Located on theEastern Portion of Suite 3169

10. Former Clarifier Located in the Western Portion ofSuite 3169

11. Typical View of Warehouse Area in the Red Hill Building 12. Typical View of Warehouse Area in the Red Hill Building

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AllWest Project xxxxx.20 Trico Pacific Center – 3169 Red Hill Avenue, Costa Mesa, California

13. Typical View of the Mezzanine Level of Red Hill Building 14. Latex Paints Used During Construction

15. Pad Mounted Transformer Located on Northern Wall ofthe Red Hill Building

16. New Electrical Enclosure and Pad Mounted TransformerLocated on Eastern Wall of the Paularino Building

17. Pole Mounted Transformers 18. Pole Mounted Transformers Located Along SouthernBoundary. View Looking East Along Southern Boundary

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AllWest Project xxxxx.20 Trico Pacific Center – 3169 Red Hill Avenue, Costa Mesa, California

19. Typical Unfished Warehouse Area of Paularino Building 20. Typical Finished Warehouse Area of Paularino Building

21. Typical Office Interior of Paularino Building 22. Roof of the Red Hill Building Looking North

23. Paularino Building Located on the Northwestern Portionof the Property Looking Northwest

24. Southwest portion of the property looking west

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AllWest Project xxxxx.20 Trico Pacific Center – 3169 Red Hill Avenue, Costa Mesa, California

25. Paularino Avenue and Adjoining Property tothe North

26. Adjoining Property to the South

27. Red Hill Avenue Adjoining Property to the East 28. Adjoining Property to the West