Department of Toxic Substances Control

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1 Matthew Rodriquez Secretary for Environmental Protection Barbara A. Lee, Director 5796 Corporate Avenue Cypress, California Edmund G. Brown Jr. Governor October 15, 2015 Dr. Gary Woods, Superintendent Beverly Hills Unified School District 255 South Lasky Drive Beverly Hills, California ADEQUACY OF REVISED REMOVAL ACTION WORKPLAN FOR PUBLIC COMMENT, AOI-1 (TEMPORARY TRAILER LOCATION), BEVERLY HILLS HIGH SCHOOL, 214 S. MORENO DRIVE, BEVERLY HILLS, CA90212 (SITE CODE: ). Dear Dr. Woods: The (DTSC) has determined that the Removal Action Workplan for Area of Interest 1 (Temporary Trailer Locations) (RAW) prepared on behalf of the Beverly Hills Unified School District (District) by Environmental Audit Inc., dated September 3,2015 and received electronically on September 3,2015 is adequate for public comment. DTSC also prepared a Notice of Exemption pursuant to the California Environmental Quality Act. The District submitted the response to DTSC comments on the RAW on October 13, The RAW specifies removal action objectives, evaluates alternatives, and describes the alternative proposed for the Beverly Hills High School (BHHS) Area of Interest 1 site (Site). The objective of the RAW is to mitigate potential risk to human health and the environment by excavation and offsite disposal of arsenic-impacted soil onsite. DTSC comments on the RAW were satisfactorily addressed and are hereby incorporated into the RAW. According to the RAW, BHHS is approximately 25 acres located at 240 S. Moreno Drive, Beverly Hills, in Los Angeles County, California. BHHS was originally built in From 1909 to the present, various areas of the BHHS were leased for oil field activities, e.g. oil wells, sumps, and aboveground storage tanks. A 120-gallon underground storage tank was removed from the BHHS in 1998, and closure letters were obtained in Some concerns on soil gas and indoor air arose in 2003, which lead to numerous investigations from 2003 to Based on the results of these investigations, it was determined that the air quality at the BHHS was not measurably different from that at other locations in the Los Angeles Basin. Land use west of Printed on Recycled Paper

2 Dr. Gary Woods October 15, 2015 Page 2 is commercial with residential development surrounding the campus in all other directions. The Site is comprised of AOI-1 within BHHS designated for placement of temporary trailers. AOI-1 is a grass play field located on the west side of the campus and the parking lot south of the play field. The area of the modified AOI-1 is approximately 2.2 acres. The District conducted a PEA investigation at BHHS in June Soil samples at the Site were tested for metals, total petroleum hydrocarbons (TPHs), volatile organic compounds (VOCs), semi-volatile organic compounds (SVOCs), organochlorine pesticides (OCPs) and polychlorinated biphenyls (PCBs). Soil gas samples were analyzed for methane, hydrogen sulfide, and VOCs. Groundwater monitoring wells were installed and groundwater samples were analyzed for VOCs and TPHs. The PEA indicates that arsenic was present in surface soil onsite at concentrations up to 79 milligrams per kilogram (mg/kg), exceeding the DTSC-approved background concentration of 12 mg/kg. PCP and dieldrin exceedances were collocated with arsenic exceedance. Consequently, DTSC determined that a removal action is necessary to address the arsenic impacted area on the Site. The RAW proposed excavation and offsite disposal of soil with elevated arsenic concentrations down to 8 feet below ground surface, and land use restrictions to prevent digging below this depth. DTSC hereby concurs the RAW is adequate for public comment and the enclosed draft NOE demonstrates the proposed removal action will not have a significant effect on the environment. The NOE will be finalized concurrently with RAW approval. The District shall publish a separate notice in a local newspaper of general circulation for a formal 30-day public comment period and meeting for the RAW. Please forward DTSC a copy of the public notice that indicates the start and end dates of the public comment period and the date of the public meeting. After the formal public comment period ends, DTSC will consider all comments received prior to modifying and/or approving the RAW. The RAW may be implemented after it is approved by DTSC. The District should place the RAW, Response to DTSC comments, this letter, draft NOE and Community Profile in the designated information repositories for public access at the start of the public comment period.

3 Dr. Gary Woods October 15, 2015 Page 3 If you have any questions regarding this project, please contact Xi hong Scarlett Zhai, Project Manager, at (714) or by atxihong.zhai@dtsc.ca.gov. or contact me at (714) or by atshahir.haddad@dtsc.ca.gov. Sincerely, Sha ir Haddad, P.E. Supervising Engineer Schools Evaluation and Brownfield Cleanup Branch Brownfields and Environmental Restoration Program ka/xsz/sh Attachment cc: Mr. Steve Bright (via e~mail) President ' Environmental Audit Inc. sbright@envaudit.com Mr. Shahir Haddad (via ) Supervising Engineer DTSC Schools Evaluation and Brownfields Cleanup Branch - Cypress Shahir.Haddad@dtsc.ca.gov Mr. Donald Greenlee (via ) Staff Toxicologist DTSC Human and Ecological Risk Office - Chatsworth Donald.Greenlee@dtsc.ca.gov Mr. Joe Hwong (via ) Senior Geologist DTSC Schools Evaluation and Brownfields Cleanup Branch - Cypress Joe.Hwong@dtsc.ca.gov Schools Evaluation and Brownfields Cleanup Branch Reading File

4 State of California - California Environmental Protection Agency CALIFORNIA ENVIRONMENTAL QUALITY ACT NOTICE OF EXEMPTION To: Office of Planning and Research From: State Clearinghouse P.O. Box 3044, 1400 Tenth Street, Room 212 Sacramento, CA 95S Schools Evaluation and Brownfields Cleanup Branch 5796 Cypress Avenue Cypress, CA Project Title: Beverly Hills High School, AOI-1 Project Location: 241 South Moreno Drive, Beverly Hills, CA County: Los Angeles Project Description: The California (DTSC), 20, Section et seq, of the Health and Safety Code is as submitted on September 2, 2015 by Environmental Aud (District). The purpose of the project is to protect human, High School (BHHS), by removing the soil impacted with level (ambient background concentration) through excavati focuses on excavating approximately 90 cubic yards of soil an appropriately permitted landfill. The RAW al~@. stitutes a Ian excavation deeper than S feet (ft) below ground' e bgs) at the will be conducted to verify achievement of the cl, ' approved by DTSC. Project activities are schedul~',~ cd, in one week. ' %, The granted under Chapter 6.S, Division Removal Action Work Plan (RAW) rly Hills Unified School District r 1 (AOI-1) of Beverly Hills the approved screening d soil. The RAW and off-site disposal to to prevent future soil DTSC approval. Confirmation sampling will be backfilled with clean imported soil Nn'\/;::.rnh~~r 2015 and are estimated to be completed Background: BHHS is an approximately 25 0 Driv:'~B~~erIY Hills, in Los Angeles County, California. BHHS was originally various areas of the BHHS were leased for oil field activities, e.g. oil wells, sumps,, A 120-gallon underground storage tank was removed from thej8~jtt$)j\la99~land ". n Some concerns on soil gas and indoor air arose in 2003, ;,Vh19r11~aatonLim~r'?~ys 006. Based on the results of these investigations, it was determine~ntm;jf the air quality,althe BHRi:Si>i1NVas not bly different from that at other locations in the Los Angeles Basin. LaIIQ\:,l!se west of BI2f~g\::i~ I with residential development surrounding the campus in all other directions. "'''''' "\~\t:\ to approve the Beverly Hills High School, Hawthorne K-S School and EI Rodeo K-S School ImprovemelltProject. :Improvement Project includes required code upgrades to structural, mechanical, electrical, and plum!:)i " all three schools, No buildings will be demolished and no new buildings will be added to the Hawthorne K, S d EI Rodeo K-S School. Two buildings at the Beverly Hills High School are proposed to be demolished to allow es to the sports fields, a new aquatic center, and a new 51,260 square foot athletic/administrative building with 3 und parking spaces. A Notice of Preparation (State Clearinghouse # S) for an Environmental Impact Report (EIR) was circulated from February 12 until March 13,2015, The Site to be addressed in this RAW is 'one of the locations where BHHS has designated the placement of temporary trailers to house students, faculty, and staff while upgrades are implemented, AOI-1 consists of a grass play field located on the west side of the campus and the parking lot south of the play field. Historically it had two buildings which were removed in The area of the Site is approximately 2.2 acres. This exemption is proposed to cover the activities included in the RAW due to the limited nature of the cleanup activities and the certainty that these activities will have no significant impact on the environment It should be noted that B~~,is also pro~ ili;; Preliminary Endangerment Assessment (PEA) investigations were conducted at the Site in June Soil samples at the Site were tested for metals, total petroleum hydrocarbons (TPHs), volatile organic compounds (VOCs), semi-volatile organic compounds (SVOCs), organochlorine pesticides (OCPs) and polychlorinated biphenyls (PCBs). Soil gas samples were analyzed for methane, hydrogen sulfide, and VOCs. Groundwater monitoring wells were installed and groundwater samples were analyzed for VOCs and TPHs. ' DTSC 1332 (03/04/08)

5 State of California - California Environmental Protection Agency The PEA indicates that several contaminants of potential concern (COPCs) at concentrations above screening levels are present at the Site. Arsenic was observed in the surface soil at concentrations up to 79 milligrams per kilogram (mg/kg), exceeding the DTSC-approved background concentration of 12 mg/kg. Pentachlorophenol (PCP) and dieldrin exceedances were collocated with arsenic exceedance. Project Activities: The project activities include: Excavation of approximately 90 cubic yards (approximately 135 tons) of soil contaminated with arsenic, PCP, and dieldrin, with depth of excavation from varying from 5 to 8 ft bgs; Off-Site disposal of excavated soil to an appropriately permitted landfill; and Backfilling of the excavated areas with clean imported soil approved by DTSC. /}:;'" The R/l:W inc.lud~s air m.onito~ing and du~t supp:~~sion measures.s~?h as, ~i_ying the ar~~ with wate~ or. covering stockpiled soil with plastic during excavation activities as these actlvltle.."" "" enerate fugitive dust emissions. The RAW also includes a transportation plan to comply with applicable regulatio[;i inimize fugitive dust. Site restoration will include replacing landscaping in areas that w~r,e the condition that existed prior to the start of construction acti Specific environmental safeguards and monitoring proced~~!:fhat are enforceable a The site will be restored to de a condition of RAW approval are included in the aforementioned plans and activities, As a resul DTSC fin t the project is exempt from further environmental review under CEQA. All other remediaf'2f@!l!11ies Ol}' HHS cam d/or related to the Beverly Hills High School, Hawthorne K-8 School and EI Rodeo K-8 School Improvement Project, if needed, shall be addressed in the forthcoming EIR. "<,;7 Exemption Status: (check,!~t~ilize, ; mitigate, or eliminate the release or threat of release of 1. The project is a minor action\~~mg. prevent, minimize, stabilize, mitigate, or eliminate the release or threat of release of hazardous waste or h2l:zar us substances. 2. The project will' not exceed $1 millii5n in cost. 3. The project does not involve the onsite use of a hazardous waste incinerator or thermal treatment unit or the relocation of residences or businesses, and does not involve the potential release into the air of volatile organic compounds as defined in Health and Safety Code Section The exceptions pursuant to California Code Regulations, Title have been addressed as follows: a. Cumulative Impact. The project will not result in cumulative impacts because it is designed to be a short-term final remedy that would not lead to a succession of projects of the same type in the same place over time. b. Significant Effect. The environmental safeguards and monitoring procedures that are enforceable and made a condition of project approval will prevent unusual circumstances from occurring so that there is no possibility that the project will have a significant effect on the environment. c. Scenic Highways. The project will not damage scenic resources, including but not limited to, trees, historic buildings, rock outcroppings, or similar resources, because it is not located within a highway officially designated as a state scenic highway. d. Hazardous Waste Sites. The project is not located on a site which is included on any list complied pursuant to Section of the Government Code. DTSC 1332 (03/04/08)

6 State of California - California Environmental Protection Agency Evidence to support the above reasons is documented in the project file record, available for inspection at the following address: Schools Evaluation and Brownfields Cleanup Branch 5796 Corporate Avenue Cypress, CA Scarlett Xihong Zhai Project Manager Name Phone # Shahir Haddad Branch Chief Name Branch Chief Signature Date Phone # DTSC 1332 (03/04/08)