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  • Letter To EMD RE Workplan Directive 10-30-17 PDF

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    Letter To EMD RE Workplan Directive 10-30-17 PDF

    Transféré par

    Joe Rubin

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    © All Rights Reserved
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    SACRAMENTO Parks and Recreation October 30, 2017 SENT E-MAIL AND US MAIL Marie Woodin Interim Chief Environmental Management Department County of Sacramento 110590 Armstrong Avenue Mather CA 95655, RE: James Mangan Park Rifle and Pistol Range, 2140 34% Avenue ~ Neighborhood Remediation oft ination Dear Ms. Woodin: The City of Sacramento (City) has been working with the County of Sacramento Environmental ‘Management Department (EMD) and the State Department of Tori Substances Control {OTSC) since ‘April of 2016 to address whether lead dust from the Mangan Rifle and Pistol Range (the "Range”) at "Mangan Park contaminated the soll inthe yards ofthe adjacent Mangan Park neighborhood, Based ‘on recent information and the extensive testing within park and the yards of homes in the ‘neighborhood, the data does not support EM’s presumption thatthe Range is the source ofthe elevated lead in soil found in some of the yards in the Mangan Park neighborhood. The City cannot ‘agree to undertake remediation when It isnot the party responsible forthe contamination, The preponderance of the evidence included in the attachments to this letter and summarized below support the premise that other historical sources of lead in the environment are the cause of the contamination, These sources include lead-based paint used in these older homes and aerial ‘deposition of lead from the combustion of leaded gasoline and aviation fuel, ‘The exhaust particulates from airplanes operating out ofthe Sacramento Executive Airport have been Identified by the US Environmental Protection Agency (EPA) as a source of aerial deposition of lea the neighborhood. Additionally, use ofthe airport during World War by the Army Air Forces as a base unt for bombardments and fighter squadrons likely impacted the sol inthe neighborhood before the homes were but. In particular, the land in the Mangan Park neighborhood was used as a ‘munitions storage area during the war, which could alse have contributed to the elevated lea levels. ‘Deparement of Pars and Recreation Director's Office 915 1 Sereet, 3 Floor Sacramento, CA 95814 Marie Woodin ‘October 30,2017, Page? Range Ventilation ‘The indoor gun range building was constructed in 1960 and operated through 2024. Unlike an ‘outdoor range, the spent lead bullets were collected in the bullet trap inside the building and were not discharged into the environment. Dust generated inside the building (a combination of carbon residue from the explosive charge and fine lead fragments from the ammunition primers and deforming lead projectiles) was exhausted through the building's roof ventilation system. The roof lexhaust vonts did not have filters to trap the lead dust particles ‘The Range was closed in ate December of 2014 after testing showed high levels of lea inside the building and around the roof vents, The testing performed by Entek Consulting Group, Inc ("Entek") was documented in its November 20, 2014 report, a copy of which was provided to EMD and DTSC. The Entek report concluded that the lead dust on the roof would likely impact the soll only in the area around the bullding. The report stated: “Entek did not assess the lead in the soilin the immediate surrounding area of the building where lead from the roof would presumably have setted from rain ‘and wash off from the raat.” No concern was mentioned regarding aerial deposition of lead dust from the roof to locations away from the Range building. Because the Range was closed, the City did rot plan on testing the sol until the building was demolished or repurposed. Park Testing Entel’s presumption thatthe impacts ofthe lead dust on the Range roof would be limited to the Immediate vicinity the Range building was found to be accurate based on the extensive testing ofthe ‘sil and hard surfaces around the Range building and inthe park. At EMD's direction, the City conducted numerous lead soil and wipe testing throughout the park in the spring of 2016, These test results demonstrated thatthe lead dust released from the bulding’s ventilation system only impacted the soll immediately round the Range building in a “halo” effect. Lead levels rapidly attenuated to well below DTSC's 80 mg/kg residential screening level for sol within about 75 feet from the building ‘Mangan Park includes a pool, playground, archery range, and soccer fields. The soil sampling and wipe sampling of the park areas included the playground located near the Range building. Both the playground equipment and the sol, as well as areas farther out from the building including the poo! deck, andthe sol inthe archery range and soccer field tested well below the state standards (Le, DDTSC soil standard and California Department of Public Health wipe standard}. The one exception was ‘2 site within the archery range 2¢ explained bolow. The test results are eenirted in the figures provided in Exhibit 2 Pad tion Flevated concentrations of lead in soil were identified only around the Range building and a small area behind the archery range targets. The sll contamination immediately around the Range building was likely caused by aerial deposition from the roof vents and lead washing off the roof via the rain gutter downspouts as predicted by Entek. The area of soil contamination found inthe archery range was likely caused by the wastewater disposal practices ofthe Range users Who recovered the lead bullet projectiles from the exterior bullet trap door and washed them using @ cement mixer +A prior Range user, Rick Stevenson, provided this historical information. Marie Weodin ‘October 30, 2017 Pages Under EMD's oversight, the soll and hardscape around the Range building and the impacted area in ‘the archery range were remedlated, Soll and hardscape were excavated and confirmation sampled Unt the areas met the state's residential cleanup standards, then backfilled with clean sol. Also, the Range building roof and exterior brick were painted with alead-sealant and the roof vents covered to prevent the release of residual lead dust into the environment. Aicstodeting Allof the tests within and adjacent to Mangan Park indicate that that the lead dust from the Range building roof ventilation rapidly deposited and did not travel far enough to impact the neighborhood, ‘The wine testing ofthe sidewalks directly across the street (34° Ave) in the neighborhood {downwind) were very low or non-detect, wth a maximum concentration of 35 ys/t (see Exhibit 1. However, EMD per ts Corrective Action Order required the City to conduct soll testing within the yards of the homes in the adjacent Mangan Park neighborhood. ‘The City’s consultant (Stantec) performed air deposition modeling to determine the area within the neighborhood that theoretically could have been Impacted by lead dust emitted from the Range bullding’s roof ventilation system. The atmospheric model (AERMOD) predicted the rate of deposition ‘of lead from the Range building and used conservative inputs which would likely over-estimate lead deposition. The model methodology and results were reviewed by the Sacramento Air Quality ‘Management District for accuracy, and subsequently approved. “The model predicted the highest lead loading rate would occur in the treet immediately n front of ‘the Range (24 Ave}, and would rapidy attenuate with distance from the Range. This prediction compared favorably with the wipe sampling data described above Results ofthe modeling were used to delineate the area of highest potential lead deposition in the ‘Mangan Park neighborhood (denoted as the “Tier 1 Study Area"), where the highest predicted lead deposition rate was 0.81 mg/f2. Using ths rate of deposition over the 54-year period ofthe Range’s ‘operation, the maximum accumulated lead concentration was calculated to be 2.8 me/k.in the top ‘one inch of soil, This concentration is negligible compared to DTSC's residential standard for lead of 80 ma/kg and indicates that aerial deposition of lead dust from the Range could not be a significant source of lead contamination in the Mangan Park neighborhood. Actual test results ofthe yards as Gescribed below were much higher than 2.8 mg/kg, indicating other much more significant ‘environmental sources of lea. Tee A Testing The Ciy undertook multiple rounds of testing of the yards at 31 homes? in the Ter 1 Study Area in accordance with workplans approved by EMD. The observed lead concentrations did not correlate ‘with the models prediction. The sollin the yards at only 12 homes had test results over DTSC’s ‘screening level, and the impacted yards were randomly dispersed as shown in Exhibit 2. Of these 12, "The boundaries ofthis Ter 1 sampling area encompassed 41 homes; however, 7 homeowners refused testing and 3 did not respond after multiple contacts ‘Marie Woodin (October 30,2017, Pages hhomes, our located a block away had lead levels that were a high or higher than homes next tothe Range. Infact, yards furthest away from the Range had the highest lead levels, and homes directly ‘across the street had lead levels well below the screening level. The test data forthe Tier 1 Study ‘rea does not support the theory that the Range operation impacted the Mangan Park neighborhood. sground Lead Levels Because all testing suggested that there were other sources of lead, the City conducted a control study to determine background levels of lea in the Mangan Park neighborhood. A "Background Study Area’ was established afew blocks east of the Tier 1 Study Area, well outside ofthe zone of potential impact from the Range based on the AERMOD lead deposition modeling. The City obtained the consent of the residents and owners of 27 homes in the Background Study Arca to test the soll in their yards, These homes were ofthe same age and construction as the homes in the Tier 1 Study ‘rea and the sampling methodology was similar to that employed in the Tier 1 Study Area. Although fewer samples were taken per yard inthe Background Study Area, the methodology was ‘haved on the background study forthe Exide battery cleanup site in Los Angeles approved by DTSC (Advanced Geosciences, 2014)? Eight yards of the homes within the Background Study Area had ‘elevated lead levels (see Exhibit 3). The yards with elevated lead levels were randomly distributed within the study acea and had similar levels of soil contamination as the yardsin the Tier 1 Study Area, \What is noteworthy is that the lead levels inthis comparison Background Study Area were substantially higher than the levels in the yards at the homes in Tir 1 Study Area near the Range. ‘Maximum lead concentrations reported from the yards a four of the homes in the Background Study ‘Area were over 200 mg/kg, whereas within the Tler 1 Study Area only one home had a maximum lead concentration of over 200 ma/kg, Itcan be concluded that the overall data fr the Tier 1 and the Background Study Area neighborhoods show similar frequency of yards with elevated lead levels, similar lead concentrations, and similar ‘andom distribution of impacted yards. The Tier 1 and Background Study Area testing conclusively shows that there are significant lead impacts in these neighborhoods caused by sources other than the Range. Other Lead Sources ‘The variety of possible anthropogenic sources of ead contamination of soll in urban areas makes it dificult to determine the contribution of any single source. The Mangan Park neighborhood was built in the early 1950s when lead was much more widespread in consumer products and industrial, processes. Potential historical sources of lead include lead-based paint, exhaust from leaded automobile and aviation fuels, use of lead-arsenate pesticides, and other sources that have slischarged lead into this environment over the past 60+ years. These sources typically account for concentrations of lead observed in older neighborhoods in urban environments (Mielke eta, 1983; Ericson and Misha, 1990; Flippell eta, 2005). The Exide battery manufacturing plant isa known aerial lead deposition sit. Marie Woodin ‘october 30, 2017, Pages Studies have illustrated that lead is persistent in the urban environment, and that the two most significant contributors of lead are lead-based paint and combustion of leaded fuel (Laidlaw and Flippeli, 2008). Concentrations of lead can frequently exceed risk-based action levels. For example, one study of a smallrhan neighborhood in Wisconsin reported concentrations of lead ranging from 400 to greater than 3,200 mg/kg, and that lead concentrations in cris tended to he higher in homo built bofore 1960 (Clark and Knudsen, 2014), & study of urban lead concentrations in Sacramento revealed a ‘ean lead concentration of 128 mg/kg, with values reported as high as 1,540 mg/kg (Solt, 2002). The researcher attributed elevated lead concentrations to a combination of industrial and vehicular pollutant sources. The Tie 1 Study Area sampling included the collection of paint chips from serval homes and the testing confirmed the presence af lead-based and lead-containing paints. Some yards had leaded paint chips in the soll which likely impacted the lead levels, ‘Additionally, the Mangan Park neighborhood has been impacted for decades by aerial deposition of exhaust particulates from leaded gasoline used in automobiles until it was banned in 1998. ‘Automobile-sourced lead has been found to he more concentrated in finer sol particulates, which are ‘more easily re-suspended, transported, and deposited in other areas (Clark et.al, 2006), Airports are another anthropogenic feature that isa significant contributor of lead impacts in the turban environment, The close proximity of the Mangan Park neighborhood to the Sacramento Executive Aiport is likely the most significant input ofthe lead particulates found in the neighborhood as explained below. ‘Aiport Operations ‘The Sacramento Executive Airport (“Airport”) opened in 1930 with three runways and has been in continuous use forthe past 87 years. The majority of aircraft using the Airport are piston driven Which require leaded fuel (‘Avgas") which i stil sold and used atthe Aiport. The EPA conservatvely estimates that 75% ofthe lead in Avgas is emitted in the engine exhaust andthe remaining 25% is retained in the motor oi ‘The Airport operated as an Army Alr Force supply depot during World War l between 1942 and 1947, {ee ExmubI a). Heavy miitary aircraft hkely emitted much nigher levels of lead than the small alreraft used today atthe Airport. The Airport also had 2 bomb storage area which extended offsite to the north within the and that is now the Mangan Park neighborhood as shown in the aerial photographs In Exhibit 4, The operation and later demolition ofthe munitions depot likely contributed to lead soll Impacts, especially during a time when industrial hygiene and remediation were not required ‘Thereafter, the Airport was used by commercial arines until the Sacramento International Airport ‘was builtin 1967, Since then, only small aircraft operate out ofthe Airport. As shown in Exhibit 5, ‘the Tier 1 and Background Study Areas north ofthe Airport are directly under the Airport's approach and departure zones. As observed during field activities, the planes ly at very low altitudes above ‘these homes for landings and takeoffs Marie Woodin (October 30, 2017, Pages ‘According to the US EPA, the Airport sin the top 5% of ALL airports inthe nation for lead emissions {Lead Emissions from the Use of Leaded Aviation Gasoline inthe Unlted States: Technical Support Document, USEPA, 2008). The aircraft operations atthe Airport conservatively emit 0.3 tons of lead ‘er year, which i three times more than the Sacramento International Airport. According to the Center for Environmental Health (CEH), leaded aviation fuel is the largest source of lead ar palution In the US, causing emissions of over 500 tons of lead per year CEH sued the private commercial plane operators at 23 airports in California under Proposition 65, including the Sacramento International Jet Center, Inc. ("Jet Center") which operates out of the Airport and sells Avgas, CEH predicted that the impact ofthe leaded aviation fuel affects a radius of ‘one kilometer or 0.62 miles out from the Airport. In 2014, a settlement was reached wil all 23, airport operators and required Jet Center to posta Proposition 65 warning sign regarding lead emissions atthe Airport. Exhibit 6 provides copies ofthe CEH documents, including a map of the potentially impacted neighborhoods next to the Airport which encompass both the Tier 1 and the Background Study Areas Summary This letter serves as the City’s response to EMD's letter dated September 27, 2017 regarding the Removal Action Workplan Response 2, Directive #5. Based on the park and neighborhood testing data previously provided to EMD and the additional information provided with ths letter, the Citys requesting EMD retract its Corrective Action Order that directs the City to prepare a workplan to ‘remediate the yards of the homes in the Tier 1 Study Area found to have elevated lead. If EMD is ‘unwilng to withdraw its order, EMD has a process for using an administrative law judge to hear disputes regarding whether an entity isa responsible forthe contamination. The City would be willing to submit this matter to a neutral party as a means of resolving this dispute. We would lke to meet to discuss the next steps. The City prefers to work cooperatively with EMD to Inform the residents in all ofthe neighborhoods near the Sacramento Executive Aiport landing and ‘approach zones ofthe precautions needed when handling scl from their yards. ‘Once this matters resolved, it's the City’s intent to inves its remaining funds allocated for the Range. remediation to remove the lead from within the interior of the building so that it can be repurposed to benefit the community. The City hopes for an amicable resolution ofthis matter to allow that work 10 begin expeditiously. ristopher Contin Director, Parks and Recreation Department Enclosures Cc: Charley Langer, County of Sacramento, EMD Diana Ruiz, County of Sacramento, County Counsel Office ‘Mike teyer, SASD Charlie Ridenour, OTSC EXHIBIT 1 EXHIBIT 2 TABLE Tler 1 Ofste Sampling Results - Total Lead CCly of Sacramento Mangan Pistol and Rifle Range - Po (EPA GOTO) -roruls In marRG Ste 1D Address Replicate 1_| Replicate 2 | Replicale 5 3 Bése bana way | —_ 150 110, 110) é .60 Dana Way 36 33 28. 7 5664 Dena Was 26 27 26 & "5668 Dana Way. 42 230 my [9 5672 Dana Was af 7 0 | S4ai brad Way. “a 4 39 H 5645 bradd Way. 38 120) 4 3 56s bradd way | _39 a8 a 4 5657 raddWay_|___61 46 47 15 5461 Bradd Way. 24 26 27 16 5665 Badd Way | _50 53 50 1B. 5673 brad Way 130) 120 33, iv 5644 Brad Was 130) 140) 130 2 5652 brada Way #2 8 Ed 22 | 56 Beall Was 35. m 5 23 | 5460 Brada Way [8 7 24 5664 bead Was 20. 0 w 25 | 5468 brada Way 2 7 76 26 36/2 badd Was 72 8 79 27 | 5657 Nolder Way a 1 ED 28 | 8661 Nokder Way ST 48 ra 30 5669 Nolder Way 7 7) 6s 3 ‘36/3 Nokler Way 3 a 33 "5660 Nokder Way 7 a a 35 | 5668 Noder Way 24 100) %4 38 5661 Holen Woy, a 7 | 3 “39 5645 Helen Way. a rica 20 5669 Helen Way, a aa 3 a1 ‘567 Helen Way. 33 90. oy lRescontial Sol Screening Level” a Nolet and abtaeviions. ‘maf llgrams parktogam 1-958 Upper Condence Level on the mean colle sing Chabysnov mathod nero Techical RegultoryCounet, 2012) 2-DISCMafie Screring Love 5) eset sol HERO Note, une 2014) told fo inciccesdatecine whieh oxceed the terourng evel Mangan Neighborhood Remedial investigation Dicrete Sol Somping Bala - teed (ParRa) ste 1D adress Min-cove tox cone, | mpl ceding es Sees Dana Way ae a Ta Stes ‘5668 Dana Way 352 234 14 130 ste? 15672 Dana Way a7 2 24/38 Ste 11 ‘5645 Brad Way 20 2s 15/32 Ste1s | seraerada we 15 760 0 133 Ste19 | 5644 Bradc Woy 98 75 2/3 Sto 23 5600 Brac Woy 545 287 19/90 Ste 26 5672 badd Way 2 190 8/31 ste35 | 5668 Nolder Way a 40 281 Sito 38 ‘661 Helen Way 657 269 22/36 Site 40 5869 Helen Woy os? eo 35/98 Steal 5673 Helen Way 5. 74 21/32 imareg-Walrars per Horas "Alora callocted January /Febssay 017, exept ter 1 ane 26 xomplod October 26 Page 1 of EXHIBIT 3 TABLE? Background Soll Sampling Results - Total Lead lly of Secramento Mangan Pistol and Rifle Range site 1D Address aoe 95% UCL G1 | sea) Jocks Lane 403 107s 86-2 | 5428 Jacks Lane. 32.1 622 8c-3 | S056 Jacks Lane 187, 02 8G-4 | _ 5465 Jacks Lane: 1100 SH25) '8G-5 | 5660 Jacks Lane 757 100.7 3G-6 | _5648.Jacks Lane 366 33.5 86-7 | 5420 Jacks Lane. 42.1 Bl 36-9 | _séas jacks tana: 101 216 242 a5 3G-10 | 5673 James Wo} 373 484 354 545 8G-11 | $661 James Way 578 4 403 137.1 8-12 | $653 James Wo} 630 28.1 228 375.1 BG-13 | 5645 Jomes Way 399 388 330 466 8G-14 | 5629 Jomes Woy 26.1 20.0 147 348 8G-15 | 5677 James Wo) or S14 446 199 86-16 | 5885 James Way MW 120 205 759 18G-17 | S489 James Woy 137 158 7 208.0 G18 | S644 Jacks Lane 3a 369. al 442 BG-19 | 5453 Jacks Lane 483 344 a5 3 1BG-20__| 5669 Jacks Lane 48.5 484 530 566 BG-21 | 5485 lacks Lane 302 30.1 4d 358 18G-22 | 5489 Jocks Lane 358 333 D7 407 58G-23 | 5676 Jacks Lane 358 362 455 580 'BG-24 | S481 Jacks Lane 488 98 79.0 Bd 18G-25 | _5652.Jocks Lane 710 375 75.0 909 6-26 | 5640 locks Lane 323 286 374 Be. 8G-27 | 8632 Jacks Lane. Te 98 704 980) 18G-28 | 5680 Jocks Lane 34s 370 394 80 [Resident Sod Sucering Level ™ 20 Noles and Abtrevitons Po- toad ‘mai ilgyams perkiogrom 1998 Upper Confelance Level onthe mean coloviaed ving Chebyshev method estate Techrict Ragulciey Counc 2012) 2. DISC Modified Screening Level (1 resin HERO Note 8, ne 2016) oid et nccates Getectiors which exceed the screening evel ‘Grange thoding icles 99% UCL valve hat exceed 89 mag EXHIBIT 4 a0 cacti ii Sacameno Map Apa (Surana Amy A Fil Sable Ay Fl Historie California Posts, Camps, Stations and Airfields Sacramento Municipal Airport (Sacramento Ariny Air Field, Suterville Auxilary Feld) ‘Sesamrts Muni! Apo han fo nlos suf Sactamato, was wed so Chico Ay AEs vas used by Seacrest Ne erga ig Cord a saved an acy ei toon Pe Comps of Engineers Data Property Desciton: The apr i apron 6 mile act Saran, The se compit 5867 ares ante cad a Exo ToPe twtaaa Ongralcnsuton ncaa he srr argo, 28 bulange, som sage are, acter esha opm He nes a ast 082 enw al nok History By tn Runge Sewanee Mune Aipat was used sb-ss to hen Amy Ail. as uted tb th th A Foie and ne Ween Sain Fie Coneand. Scam help Aor wae er {TiS reams unary Decanting froma pve ner on Hover 28, 182. ron he Cy of Sra tetany 042 apd Novenbe oak The O.Sone lense was sed dol srage and ctor eelngeeums, walersupn Sores a 2 Seager dose syste tens be spe aes unwaye (8 SE) wn: aon naan fl aan, ang ahd gh pens fener tnd stason ata 3 ow lng ‘cn Decenbor 20,046, 058.21 sce ware rprted a ences. The 825 aes wae wenforesto the We Ass Aination (AA) ‘Share 1H? along win tb sro esas pope. To gowoneen cng taugh Waa, cance ie S057 aces Be ly of ‘floctive ly 1, 1947, Units That Served at Sacramento Municipal Airport in World War I + ann any Ae oe ei mac 208 Mea ae es ° fen an ment ete Sos Extract, US Army Air Forces Directory of Airfields, January 1945 pnw niyo rSeraneslispAget ue MANGAN PARK. NEIGHBORHOOD (Tien 1 STUDY ‘AREA) E3 ENERCON 1947 Aetial Photograph tose | Project No: CTYSACOO4 City of Sacramento NURSERY PROPERTY 1920 34th Avenue Sacramento, CA 95822 i (nena stuor ann) EXHIBIT 5 i @=Chear Zone a @ = Apmtoach- Departure Zone 1 oto a ago et @ = Aporoact- Departure Zone 2 i 7 @=Cvertight Zone Figure 11 ‘Sacramento Executive Airport Safety Zones EXHIBIT 6 sapi7 ‘Ava Pan CEH | Cnr Enver lh JOM OURMALNGLIST TAKEACTION aMPLoYMENT DONATE WHY WERE HERE CAMPAIGNS RESULTS GET INVOLVED NEWS AEVENTS WHOWE ARE Map: California Neighborhoods Did You Know? Affected by Lead from Aviation ornare resisvenes Fuel {SYNTHETIO CHEMICALS Ifyou lve nea an spotter smal 80,000 regional spor or age part that is too used by smal planes, you know ha ar queliyprblens ae a daly Pear er en realy Lead polation fom smal FOR WOR EPA HAS ‘planes that continue to use load REGUIRED SAFETY TESTING based fal major problem, 0 since lead can advrsaly affect the nervous sytem, Kidney unten, mune 0.25% system, productive and developmental systems and te cardovesclar system CEH took lgal action in Calfornla to adress the pollution problem fom lead based aviation ful, and we have reached ground-breaking logal My Blog agrooment to help alleviate lead potion around 23 Galfomia airports, We ‘also expec ou egal acon wll romp the aviation industry to adopt lead-ree ‘el more quick, sparing the air around aiports nationwide. ‘NEW Report: Myths & Realities of Leased Aviation Fuel ‘Do you live near one ofthe sports on the map below? Cc th spt oan to 800 @ map ofthe neighborhood around the Tump Threatens Our rma airports with sigifieant lead emissions. (Airport sti below the Drinking Weter ‘mep) ‘aneveMLER AUGUST 25 2017 You'll Never Belive What ‘Maine Just Did! gunn ahora Understanding the Toxic (Chemical Gap Bob Hope Airport (SUR- Burbank) Brackett Feld (POC La Verna) ‘Brown Fleld Municipal Airport (SDM- San Diego) Buchanan Field (COR- Concord) Camarillo Alport (KCMA- Camarito) El Monte Airport (EMT-EI Monts) Fresno Yosemite International Airport (FAT Fresno) Hayward Executive (HWD- Hayward) John Wayne Airport (SNA- Santa Ana) 1 Lang Beach Airport (.G8- Long Beach; formarty Daugherty Fe) aru 1 Loe angles Interatons Apt (AX-L2e Angles) Success nRekng Toxo + Naadows Feld (@F.- Bxon0) homie Out of mitre | Montgomery Fd (YE- San Diogo) oar {Mapa County Aor (4° Napa) oe 1 atiad ntrnatona! Airport (OX Okand) 1 palo ito Apotex. Fale A) serous 1 Raitattvow Atpor (Sno) 1 SectomentoExabutive Ar (2AC- Sarat) + Sans obispo County Roglona pot (S8P- San O30) + Santa Barbara Munepal lpr (San Barbar) + Sum Monen Munepl Alport (SM- Sara nis) ‘Nan Rye Aiport (Van i) 5 Zam iat (TON Trance) If you Sve near a small alpor that snot on ur ist, contact CEH (caroline@ceh.org) fr more information. You can also sign up for our ‘malin itt stay infrmod on this, and also receive many other health tps {for you chiron and fami. Leaded Gas: Out of Cars But Stillin Planes you were driving 2 car bere 1995, you may remember that cars sometimes used “regula” (leaded gasoline). Leaded gasoline was the only gasoline available between tho 1920s and the early 1970s, Between 1974 and 1995, the use of leaded gas for cars was gradually phased out, The US Environmental Protection Agency callod this “one ofthe one of the great environmental achievemantsof ll ime,” noting that "thousands of ons of lead hhave boen removed fom the al, nd blond levels of fad in our chikren are ‘dow 70 percent This means that milion of chidren willbe spared the painful consequences of lead poisoning, such as permanent nerve damage, ‘anemia or mental retardation * White cars were required to use unleaded fuel after 1995, today small propeller planos (often called general aviation planes) and some helicopters ooo = snot? ve La Pn: CE | Cantar Eonar Heath =o il allowed to use leaded aviation gas (avgss). Curent, loaded avs is the largest source of lead alr pollution inthe US, causing omissions of over ‘500 tons af ead por yoar. Recent research has found that children ving ne=r ‘Bene aviation airports have higher blood lead lvels than citron living farther away, and studies have Enked high childhood lead levels oa host of serous health probloms, ‘STAY INFORMED SUBSCRISE WHY WE'RE HERE CAMPAIGNS RESULTS GET INVOLVED WEWS & EVENTS WHO WE ARE CEH protects people from toxic chemicals by working with communities, consumers, workers, government, and the private sector to demand and support business practices that are safe for public health and the environment. pans avgst 540944 98009 unm ery ‘spoowiogysisu pasode A spoowoqutiu pasodi. spooisoqubiat pecodke fi spoowloqysteu pasode Ajenustog ‘insedxo jenusyod yo Bary ‘Auepuneg uodiy aunnoerg cwuowiioes Lp ody AVES emai Llp Sandexg o1ueWeloes LEXINGTON LAW GROUP Mark N Tod, State Bar No, 168389, Hla isl Sate Ber No 213209 503 Divisadero Srt San Franeise, CA 94117 ‘Telepane: (15) 913-7800, assis 415) 75-8112 rmtodzo@lexlavpoup com Autones for lant ‘CENTER FOR ENVIRONMENTAL HEALTH ‘SUPERIOR COURT OP THE STATE OF CALIFORNIA, COUNTY OF ALAMEDA (CENTER FOR ENVIRONMENTAL HEALTH, ‘non-profit corporation, Plant, AERODYNAMIC AVIATION, etal Defendant, TICES BAY OF ORDER AND CONS DON ; Lied bERn DEC 12 704 ‘Cun OF IO COURT By ee (Case No. RG 11-600721 ASSIGNED FOR ALL PURPOSES TO: Sage Wye Carl, Dep. 21 NOTICE OF ENTRY OF ORDER AND CONSENT JUDGMENT. CComplin Filed: Qetober20,2011 ‘ea Date None 1] 10 ALL PARTIES AND THER COUNSEL.OF RECORD: 2 ‘Plas tke nize hat on Deerbe 10, 2014, tbe Cou entero the flowing 3] document “ 1. Order Graig Plisits Motion for Court Approval and Ext of Consent s Jaden. copy of which attached hereto as Exit 1 6 | 2 Amended Consent agent copy of wich is tached hereto as Exit 2. 7 8 | Date: December 10,2014 Respect subited, ° INGTON LAW GROUP : Lk Wak Todo ‘Atom fer Pant B ‘CENTER FOR ENVIRONMENTAL HEALTH ‘GCE OF ETRY OF ORTER AND NST HUDONENT 10 2 b 4 15 6 ” ts 2» a 2 ™ 25 Eo 28 LEXINGTON LAW GROUP ‘Mati N.Todzo, State Bar No. 168589 ‘Rowand sch, State Bat No, 213209 ‘503 Divisadero Steet, Son Francisco, CA 94117 ‘Telephone (415) 913-7800 cs: (15) 759-4112 inl@ilavgnpean sch expos Alone fer Pit (CENTER FOR ENVIRONMENTAL HEALTH DEC 0.9 208 ‘CLERK pr me surequon COURT Py Enea} enusy SUPERIOR COURT OF THE STATE OF CALIFORNIA ‘COUNTY OF ALAMEDA ‘CENTER FOR ENVIRONMENTAL HEALTH, 8 non-profit compration, ABRODYNAMIC AVIATION, ea, Defends, Case No, RG 1.600721 SstounD noe AL PuRvoses To Cavill, Depertneak 31 t )| ORDER GRANTING PLAINTIFV’S MOTION FOR COURT APPROVAL AND ENTRY OF CONSENT JUDGMENT ‘Meath & Safety Code § 252.160) ate: December 10,2014 ‘Tine: B30em. Reservation Number: 1530129 (0» December 10,2014, 08:30am, Plant Center for Envconmental Heals (CEI) Motion for Cout Approval and Entry of onsen Judgment came on for eating before this Cours in Departnen 2, the Honorable Wyre Caril pesiding, The Amended Consent Dingman presented for approval is between CEH and he following defendants: 1. FRO Setting Defendants 1 2 3 n 18 8, 20. ‘ic 85 oe, Comm Aviation ‘Ae Ruts erational LLC Ai, fe APP Propet da APP fet Cente, socesor Airport Propety riers LLC a APP Jet Center ‘Aelia Reid Aviation LLC -Aresian Aeprts Copration Aameityers of Celioria Aan Avision Comoran; Atlantic Aviston FBO, Ine Alani. on of Senta Mone, LP jl severally ‘Aviation Constants, ne, ta San Las Jet Center Dosiness et Cer Okland, LP Coloria a Nie te, da Nie Air oi Case & Cooke Aviation Services, In, (Chae! sands Aviation Ine, aise, ne Lanchir Cop. iv Sen Diego Jet Center Landini Aviston Gluing Landmark Aviation GSO-SAN, LLC and Piedmont Hawthorne Aviation, LLC), oily and severly Loyd Avion Maguire Avision Group, LC Napa et Cents, ne Pcie States Aviation, ine a Ross Areal ne. eee 2, m 2s 26. ‘Signature Fight Support Cosprtion South Bay Aviation Ie Sun Aiea, LC ‘Van Naye Skyways dv Mion Air Burbank 1, Disteibotor Setting Defendants 2 a 4 ‘iret Corporation and Werld Pus Services Cororatin, jointly and seveally ‘Avfuel Corporation aster Aviation Fel, ne Downstream Aviation, LP ‘Aier fll consideration of he pins and authorities ad veltd pleadings wbmited he Court rules a fellows: IIS HEREBY ORDERED tht Plitf?’s Motion for Appoval and Enty of (Consent Judgment is GRANTED. Pursuant oan in aeardance with Heath & Safety Code §25249.10(4, th Court makes the following fidngs with respect othe Amended Consent dent “The Amended Consent Judgment ensures compliance wit the Proposition (65 warning requirement, “The storeys fee award in the Amended Consent Judgment is rneonable ner Califo au and 2 3, The vil penais and payment cw of evil penalties be Amended a Consent edges reson a on sit Hien ah 3 Softy Cote 2529.00). 4 ‘oli oft igs st forte, he onset gent isboedy 5| arrnovsn, ‘ 7] reissooxpen, 5 | owen (2/7 [2014 » h n B 4 1s 6 ” 8 » 2» a 2 * 2% 2% n 2% 3 e e enpege BB DEC 9 204 a SERA se SUPERIOR COURT OF THE STATEOF CALIFORNIA ‘COUNTY OF ALAMEDA (case Na RG-11-600721 9] AMENDED CONSENT JUDGMENT (CENTER FOR ENVIRONMENTAL MEALTE, ‘en preft corporation, Pani, [AERODYNAMIC AVIATION, era Defendants. 1. INTRODUCTION 1.1 The pts to his Consent dye (Pats ae Pai te Comer for nionmerta Health (*CEN) andthe undersigned dfendntson Ebi A le “Sting Defenan 12 Commencing n May 2011, CEN served malig 60.019 Notices of Viton under Proportion 65 (Phe Sa Deakin Water nd Tosi atrcement Act of 19865, Califo He & Safty Cade $9 252623, ef), loging the ets mes hase nes woe Propeson 65 by exposing eons ea, 2 wel seed and compounds fale, “Lend” conuined in ended viaon gain (*Avgas) without st providing a lear and resonable Popasin 65 wing 13 On dune 30,2011, several ofthe defendants in his case ied an ation in the United Sats istit Cove forth Eastem Disbet of California against CEH, the California Attorney Genera, arth Acting Director ofthe Califia Office of Enviromental Health Hazard Assesment (geter the “Federal Defendants"), Te federal pits sought declaratory and injunctive eli alegng thet CEHs Propastion 65 clams were preempted by federal aw. Feder Defendants motions to dismiss were granted, and the atin was dismissed on October 1,201, 14 OnOetober20, 2011 CEH fe the ation ele CEH, Aerodynamic Aviation, et ‘a, Case No. RG 11-60072, in the Superior Cout of Clif for Alamed County. On October 25,201, CEH ile it First Amended Complaint. On Jly 17,2012, CEH filed the operative Second Amends Cmplunt (he “Complain” 15 ach Setting Defeat dsbutes coffers Avs forsale inthe State of Caifoia ‘chs done so inthe past! The Seting Defendants ae composed of fied base operators and other business tht fer Avg for rt sl spots Calon (he “FBO Setting Defendants") and csributr of Avg tha istibute Avgas to FHOs and other businesses that offer Avgs for ai el tims in California (he “Distr Setling Defenders), The FBO Seng Defends ogther operate 24 diferent apo in Califia, In some instances, number of

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