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Langer. Charley
Karl Kurka
Woodin. Marie; Pace. Chris; Bailey. Ryan; Meyer. Michael (SDA); Ruiz. Diana; Christopher Conlin; Lori Bauder;
Ridenour, Charlie@DTSC; Doran, Neil; Sheryl Patterson
CDPH Certification for Those Working at the James Mangan Park Rifle and Pistol Range Site
Thursday, August 04, 2016 10:33:41 AM

Hi Karl,
There have been a number of emails back and forth about the necessity of CDPH certification for
those working at the James Mangan Park Rifle and Pistol Range site. This email is to explain EMDs
position and request the Citys cooperation with respect to this issue. If we cannot come to
agreement, EMD will need to amend the Corrective Action Order.
EMDs position is that the work at this site includes the evaluation and abatement of lead hazards at
a public building, as defined by Title 17, California Code of Regulations, Division 1, Chapter 8. EMD
also asserts that all those working at the site to evaluate and abate lead hazards are required by law
to be certified by CDPH until the lead hazard has been abated.
Chapter 8 defines a public building in 35045 as a structure, or part of a structure, and its land,
which is generally accessible to the public. EMD disputes that a temporary closure and fencing of a
structure that was previously generally accessible to the public changes the definition of public
building. If that were the case, then abatement of every public building could be conducted
outside the requirements of Chapter 8 by simply temporarily closing the building to the public and
erecting a fence. That is not a reasonable interpretation of 35045 and is contrary to the purpose of
this regulation. Please note that the definition of public building also includes its land.
The definition of lead hazard includes lead-contaminated dust and lead-contaminated soil (
35037). Lead-contaminated dust is defined in 35035 to include dust that contains an amount of
lead equal to, or in excess of, four hundred micrograms per square foot (400 g/ft2) for exterior
floor and exterior horizontal surfaces. Lead-contaminated soil is defined in 35036 as bare soil
that contains an amount of lead equal to, or in excess of, four hundred parts per million (400 ppm) in
childrens play areas and one thousand parts per million (1000 ppm) in all other areas.
Thus, EMD requires that all onsite workers evaluating and abating lead hazards be CDPH-certified
until the lead hazards have been removed. Please let me know by the end of the day, Thursday,
August 4, whether the City is willing to agree to this requirement.
Thank you.

Charley Langer
County of Sacramento
Environmental Management Department
Site Assessment and Mitigation Section
10590 Armstrong Avenue, Suite A
Mather, CA 95655
(916) 875-8474

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