Cupertino City Council
July 1, 2025

RE

MOVAL ACTION WORKPLAN

SEDGWICK ELEMENTARY SCHOOL EXPANSION PROJECT
10480 FINCH AVENUE, CUPERTINO,

SANTA CLARA COUNTY, CALIFORNIA
(Site Code: 204271)
Prepared for:

CUPERTINO UNION SCHOOL DISTRICT
JANUARY 2018
Attachment D

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TABLE OF CONTENTS
Page

1.0 INTRODUCTION ............................................................................................ 1-1

1.1 REMOVAL ACTION OBJECTIVES ..................................................... 1-1

1.2 PROJECT DESCRIPTION .................................................................. 1-2

2.0 BACKGROUND ............................................................................................... 2-1

2.1 SITE LOCATION AND DESCRIPTION ............................................... 2-1

2.1.1 Site Name, Address and Size .................................................... 2-2

2.1.2 Contact Person, Mailing Address and Phone Number ................ 2-2

2.1.3 Assessor’s Parcel Numbers and Map ......................................... 2-2

2.1.4 Ownership ................................................................................. 2-2

2.1.5 Township, Range, and Section ................................................... 2-2

2.2 OPERATIONAL HISTORY AND STATUS .......................................... 2-2

2.3 TOPOGRAPHY ................................................................................... 2-3

2.4 GEOLOGY AND HYDROGEOLOGY .................................................. 2-3

2.5 LAND USES, SENSITIVE RECEPTORS, ECOSYSTEMS AND
CULTURAL RESOURCES ................................................................. 2-3

2.6 METEOROLOGY ................................................................................ 2-4

2.7 PREVIOUS SITE ACTIONS ................................................................ 2-4

2.7.1 Phase I Environmental Site Assessment .................................... 2-4

2.7.2 Preliminary Environmental Assessment ..................................... 2-5

2.7.3 Supplemental Site Investigation ................................................. 2-7

3.0 NATURE, SOURCE, AND EXTENT OF CONTAMINANTS ............................. 3-1

3.1 NATURE AND SOURCE OF CONTAMINANTS ................................. 3-1

3.2 EXTENT AND VOLUME OF CONTAMINANTS .................................. 3-1

3.3 HEALTH EFFECT OF CONTAMINANTS ............................................ 3-2

3.4 RECEPTORS POTENTIALLY AFFECTED BY THE SITE .................. 3-3

4.0 RISK EVALUATION AND PRELIMINARY CLEANUP GOALS ........................ 4-1

4.1 RISK EVALUATION ............................................................................ 4-1

4.1.1 Environmental Screening Risk Evaluation ................................... 4-2

4.2 VOLUNTARY CLEANUP AGREEMENT ............................................. 4-2

4.3 CLEANUP GOALS ............................................................................. 4-2

5.0 ENGINEERING EVALUATION / COST ANALYSIS (EE/CA) ........................... 5-1

5.1 REMOVAL ACTION SCOPE ............................................................... 5-1

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TABLE OF CONTENTS (CONTINUED)
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5.2 IDENTIFICATION AND EVALUATION OF REMOVAL ACTION
ALTERNATIVES .................................................................................. 5-1

5.2.1 EE/CA Alternative Evaluation Criteria.......................................... 5-1

5.2.2 Description and Comparative Analysis of RA Alternatives ........... 5-2

5.2.2.1 No Action .......................................................................... 5-2

5.2.2.2 Excavation and Offsite Disposal ........................................ 5-2

5.2.2.3 Treatment ......................................................................... 5-3

5.2.2.4 Engineering and Institutional Controls ............................... 5-3

5.3 DESCRIPTION OF RECOMMENDED REMEDY ................................ 5-4

5.4 COST ESTIMATES OF RECOMMENDED REMEDY .......................... 5-4

6.0 APPLICABLE OR RELEVENT AND APPROPRIATE REQUIREMENTS ........ 6-1

6.1 CHEMICAL-SPECIFIC ARARS ............................................................ 6-1

6.1.1 Risk Screening Levels ................................................................ 6-1

6.1.2 Air Quality Management ............................................................. 6-2

6.1.3 Health & Safety Plan ................................................................... 6-3

6.2 ACTION-SPECIFIC ARARS ................................................................ 6-3

6.2.1 Waste Management ................................................................... 6-3

6.2.2 California Environmental Quality Act (CEQA) .............................. 6-4

6.2.3 Stormwater Discharge ................................................................ 6-7

6.2.4 Quality Assurance Project Plan (QAPP) ...................................... 6-8

6.2.5 Others ........................................................................................ 6-9

6.3 LOCATION-SPECIFIC ARARS ............................................................ 6-9

6.3.1 Public Participation ..................................................................... 6-9

6.3.1.1 Community Assessment ................................................... 6-9

6.3.1.2 Community Profile Report ................................................. 6- 10

6.3.1.3 Public Participation Activities............................................. 6- 10

7.0 REMOVAL ACTION IMPLEMENTATION ........................................................ 7-1

7.1 FIELD DOCUMENTATION ................................................................. 7-1

7.1.1 Field Logbooks ........................................................................... 7-1

7.1.2 Chain-of-Custody Records ......................................................... 7-2

7.1.3 Photographs ............................................................................... 7-3

7.2 SITE PREPARATION AND SECURITY MEASURES ......................... 7-3

7.2.1 Delineation of AOCs .................................................................. 7-3

7.2.2 Utility Clearance ......................................................................... 7-3

7.2.3 Security Measures ..................................................................... 7-3

7.2.4 Contaminant Control .................................................................. 7-4

7.2.5 Cultural Resources Consideration .............................................. 7-4

7.2.6 Biological Resources Consideration ........................................... 7-5

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TABLE OF CONTENTS (CONTINUED)
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7.2.7 Noise Control ............................................................................. 7-5

7.2.8 Permits and Plans ...................................................................... 7-5

7.3 WORK ZONES ................................................................................... 7-5

7.3.1 Exclusion Zone .......................................................................... 7-5

7.3.2 Decontamination Zone ............................................................... 7-5

7.3.3 Support Zone / Staging Area ...................................................... 7-5

7.4 EXCAVATION ..................................................................................... 7-6

7.4.1 Trenching, Excavation, and Confined Space Entry ..................... 7-6

7.4.2 Soil Staging and Storage Operations ......................................... 7-6

7.4.3 Waste Segregation Operations .................................................. 7-7

7.4.4 Decontamination Procedures ..................................................... 7-7

7.4.5 Excavation Plan ........................................................................ 7-7

7.5 METEOROLOGICAL AND AIR MONITORING .................................. 7-8

7.5.1 Meteorological Monitoring .......................................................... 7-8

7.5.2 Site Air Monitoring ...................................................................... 7-8

7.5.2.1 Site Worker Air Monitoring................................................. 7-9

7.6 DUST CONTROL PLAN .................................................................... 7-9

7.7 SAMPLING AND ANALYSIS PLAN .................................................... 7-10

7.7.1 Waste Profiling Sampling ........................................................... 7-10

7.7.2 Confirmation Sampling ............................................................... 7-11

7.8 TRANSPORTATION PLAN FOR OFF-SITE DISPOSAL .................... 7-12

7.9 BACKFILL AND SITE RESTORATION ............................................... 7-13

7.10 VARIANCE OR EXPLANATION OF SIGNIFICANT DIFFERENCE (ESD) 7-13

7.10.1 Fundamental, Significant, or Minor Changes ............................ 7-13

7.10.2 ESD Process ............................................................................ 7-13

8.0 PROJECT SCHEDULE AND REPORT OF COMPLETION ............................. 8-1

9.0 REFERENCES ................................................................................................ 9-1 TABLES
Page
Table 4-1: Comparison to Screening Levels ............................................................... 4-2 Table 4-2: Cleanup Goals ......................................................................................... 4-3 Table 6-1: Dust Exposure Levels .............................................................................. 6-3 Table 7-1: Site Air Monitoring Action Levels .............................................................. 7-9 Table 8-1: Schedule of Tasks ..................................................................................... 8-1

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PLATES
Page
Plate 1-1: Site Location .............................................................................................. Plate 1-1 Plate 1-2: Site Plan .................................................................................................... Plate 2-1 Plate 3-1: Areas of Concern ...................................................................................... Plate 3-1 Plate 7-1: Organization Chart .................................................................................... Plate 7-1 Plate 7-2: Work Zones ............................................................................................... Plate 7-2 Plate 7-3: Excavation Plan ........................................................................................ Plate 7-3 Plate 7-4: Confirmation Soil Samples ........................................................................ Plate 7-4

APPENDICES
APPENDIX A: DTSC’S FINAL PEA AND SSI APPROVAL LETTER
APPENDIX B: ASSESSOR’S PARCEL MAP
APPENDIX C: CONCEPTUAL SITE MODEL AND DATA SHEETS
APPENDIX D: NOTICE OF EXEMPTION
APPENDIX E: COMMUNITY PROFILE REPORT
APPENDIX F: DTSC COMMUNITY UPDATE
APPENDIX G: HEALTH & SAFETY PLAN
APPENDIX H: QUALITY ASSURANCE PROJECT PLAN
APPENDIX I: TRANSPORTATION PLAN
APPENDIX J: DTSC ADVISORY ON IMPORTED CLEANFILL MATERIAL

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REMOVAL ACTION WORKPLAN
Sedgwick Elementary School Expansion Project
Cupertino, Santa Clara County, California
(Site Code: 204271)

1.0 INTRODUCTION
Padre Associates, Inc. (Padre), on behalf of Cupertino Union School District (District), has prepared this Removal Action Workplan (RAW) for the Sedgwick Elementary School Expansion Project, located at 10480 Finch Avenue in Cupertino, Santa Clara County, California (Project Site). The Project Site is identified on Plate 1-1: Site Location and Plate 1-2: Site Plan.

This RAW is based on the results of the following documents prepared by Padre:
• Final Preliminary Environmental Assessment, Sedgwick Elementary School Expansion Project, 10480 Finch Avenue, Cupertino, Santa Clara County, California dated September 15, 2015; and
• Supplemental Site Investigation, Sedgwick Elementary School Expansion Project, 10480 Finch Avenue, Cupertino, Santa Clara County, California (Site Code 204271) dated January 7, 2016.

The Preliminary Environmental Assessment ( PEA) and Supplemental Site Investigation (SSI) defined the extent of organochlorine pesticides (OCPs) and lead in surface soil at the Project Site exceeding U.S. EPA Regional Screening Levels (RSLs) or DTSC-modified screening levels.

Copies of the DTSC letters approving the PEA and SSI reports are presented in Appendix A.

This RAW includes a detailed engineering plan for conducting the selected response action (RA) for each chemical of concern ( COC) and the goals to be achieved by the RA, as required by the California Health and Safety Code (H&SC) section 25323.1. The RAW is also consistent with the criteria specified in the H&SC section 25356.1(h).

1.1 REMOVAL ACTION OBJECTIVES
The removal action objectives (RAOs) have been established to be protective of human health and the environment. The RAOs include:
• Minimize exposure of humans to COC in soil through the inhalation, dermal absorption, and ingestion exposure pathways;
• Minimize potential for migration of COC from soil to other media; • Establish Cleanup Goals (CGs) equivalent to U.S EPA RSLs or DTSC -modified screening levels; and
• Establish post-RAW site conditions that do not pose a significant risk to human health, safety or the environment.

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1.2 PROJECT DESCRIPTION
The District purchased the Project Site in 2017 as part of the future expansion of Sedgwick Elementary School. At this time, no specific plans have been developed, however the expansion project will not result in the addition of classrooms or students to the existing elementary school.

If needed, public water will be provided by the San Jose Water Company, and public sewer will be provided to the Project Site by the Sunnyvale Sanitation District.

PROJECT
SITE

SEDGWICK ELEMENTARY
SCHOOL

PHIL LANE
FINCH AVE.

STENDHAL LN.
associates, inc.

ENGINEERS, GEOLOGISTS &

ENVIRONMENTAL SCIENTISTS
PLATE 1-2
DR. BY
AC
APP. BYSITE PLAN
DATE
PROJECT NO.
7/13/17AJK 1601-3361
SOURCE: GOOGLE EARTH MAP DATED NOV. 2016

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2.0 BACKGROUND
The Project Site consists of approximately 1.48 acres of residential land and, which is identified by the Santa Clara County Assessor’s Office as Assessor Parcel Number (APN) 375- 40-067. The Project Site is located adjacent to the northwest corner of the Sedgwick Elementary School property at 10480 Finch Avenue in Cupertino, Santa Clara County, California.

The Project Site was previously owned by F.A. Pestarino Jr. Trustee, and had been owned by the Pestarino family since the 1930s. The property historically contained a prune tree orchard.

According to a review of available historical aerial photographs, the Project Site was planted as an orchard from at least 1939 through the late 1950s. The existing residential building is present in a 1956 aerial photograph.

In addition to the residence, the Project Site contains a workshop (wood- framed with corrugate metal roof) located at the southeast corner of the Project Site. Located south and adjacent to the workshop are two, small, single-room dwellings that are wood-framed and situated on concrete blocks.

Potential chemicals of concern ( COC) identified at the Project Site included residual pesticides and arsenic in soils associated with historic agricultural use; residual pesticides associated with termiticides and ant control in surface and subsurface soil from historic and existing buildings; the potential for lead in soils from the weathering of lead- based paint from historic and existing buildings; the potential for polychlorinated biphenyls (PCBs) in soil from the weathering of caulking around old window frames of historic and existing buildings; and the potential presence of total petroleum hydrocarbons (TPH) and volatile organic compounds (VOCs) in and soil and soil gas beneath the Project Site associated with a former gasoline underground storage tank (UST).

Padre completed a PEA for the Project Site dated September 2015, and an SSI dated January 2016. The purpose of the investigations was to establish whether a release or potential release of hazardous materials substances, which pose a threat to human health via ingestion , dermal contact, and inhalation exposure pathways exist at the Project Site. The results of the PEA and SSI identified the presence of chlordane (pesticide) and lead in soil above residential screening levels. Therefore, further action was recommended to eliminate, reduce, and/or mitigate the identified COC at the Project Site. The results of the PEA and SSI are discussed further in Sections 2.7.2 and 2.7.3 of this report.

2.1 SITE LOCATION AND DESCRIPTION
The Project Site is located at 10480 Finch Avenue in the eastern portion of City of Cupertino, Santa Clara County, California. Cupertino is located approximately 36 miles southeast of downtown San Francisco and 8 miles southwest of downtown San Jose. Additionally, Cupertino is located in Santa Clara County and is bordered by the City of Sunnyvale and a small portion of the City of Los Altos to the north, the cities of Santa Clara and San Jose to the east, the City of Saratoga to the south, and unincorporated Santa Clara County to t he west ( Apple Campus 2 Project EIR, June 2013).

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The Project Site is bordered to the north by Phil Lane, beyond which is residential property; to the east and south by Sedgwick Elementary School; to the west by residential property; and to the northwest by Finch Avenue, beyond which is residential property.

2.1.1 Site Name, Address and Size
Site Name: Sedgwick Elementary School Expansion Project Site Address: 1 0480 Finch Avenue, City of Cupertino, California, 95014 Site Size: 1.48 acres

2.1.2 Contact Person, Mailing Address and Phone Number
Travis J. Kirk, Director of Facilities and Modernization Cupertino Union School District
10301 Vista Drive
Cupertino, CA 95014
Phone No. (408) 252-3000

2.1.3 Assessor’s Parcel Numbers and Map
The County of Santa Clara identifies the Project Site as Assessor’s Parcel Number (APN):
375-40-067. A copy of the Assessor’s Parcel Map is presented in Appendix B.

2.1.4 Ownership
The Project Site is owned by the Cupertino Union School District.

2.1.5 Township, Range, and Section
The Projec t Site is located in Section 19, Township 7 South, Range 1 West, of the Cupertino Quadrangle, California USGS 7½ -Minute Series, Topographic Map ( 1991).

Approximate latitude and longitude of the central area of the property are identified to be:
• Latitude (North) 37° 18’ 56.5194” (37.3157)
• Longitude (West) - 122° 0’ 35.2794” (-122.0098)

2.2 OPERATIONAL HISTORY AND STATUS
The Project Site consists of 1.48-acres of residential use property, and is located adjacent to the northwest corner of the Sedgwick Elementary School property. Prior to the 2017 purchase of the Project Site by the District, the property had been owned by the Pestarino family since the 1930s. The property historically contained a prune tree orchard from at least 1939 through the late 1950s and the existing residential building is present in a 1956 aerial photograph.

Additionally, the Project Site contains a workshop (wood- framed with corrugate metal roof) located at the southeast corner of the Project Site. Located south and adjacent to the workshop are two, small, single -room dwellings that are wood- framed and situated on concrete blocks.

These dwellings were the original residential structures.

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2.3 TOPOGRAPHY
Based on a review of the USGS 7.5 -minute series topographic map Cupertino Quadrangle, California, 1991 (photorevised 1982), the Project Site lies at an approximate elevation of 205 feet above mean sea level (msl) near the center of the Project Site. The overall topographic gradient for the surrounding area is to the northeast. The Project Site is relatively flat with storm water runoff directed northerly towards storm drains located in the adjacent street.

Calabazas Creek is located approximately 1,600- feet northwest of the Project Site and flows in a northeasterly direction. Saratoga Creek is located approximately 0.75 miles west of the Project Site and flows in a northerly direction.

2.4 GEOLOGY AND HYDROGEOLOGY
The Project Site is located within the Coast Ranges Geomorphic Province of California.

The Coast Ranges stretch approximately 600 miles from the Oregon border to the Santa Ynez River and fall into two sub-provinces: the ranges north of San Francisco Bay and those from the bay south to Santa Barbara County. The northern ranges lie east of the San Andreas Fault zone, whereas most of the southern ranges are to the west. The province contains many elongate ranges and narrow valleys that are approximately parallel to the coast, although the coast usually shows a somewhat more northerly trend than do the ridges and valleys. Therefore, some valleys intersect the shore at acute angles and some mountains terminate abruptly at the sea. The northern Coast Ranges are higher than the southern where Solomon Peak located in Trinity County rises to an elevation of 7,581 feet, the highest point in the Coast Ranges (Norris and Webb, 1990).

According to the United States Department of Agriculture, National Resources Conservation Service, Web Soil Survey (http://websoilsurvey.nrcs.usda.gov/app/ ), two soil types
are identified for the Project Site. Soils located within the southeast half of the Project Site consist of Urban Land-Stevens Creek Complex located on 0 to 2 percent slopes. Native soils consist of sandy loam, silt loam, and silty clay loam. Soils in the northwest half of the Project Site consist of Urban Land-Elpaloalto Complex located on 0 to 2 percent slopes. Native soils consist of clay loam and silty clay loam. Both of these soils are well drained and runoff is slow.

A review of the State Water Resources Control Board’s GeoTracker website (http://geotracker.waterboards.ca.gov), identified groundwater assessment activities that were conducted for a facility located approximately 0.56 miles northeast of the Project Site.

Reportedly, the depth to first groundwater at the referenced site is greater than 80 feet bgs, and groundwater is inferred to flow in a northeast direction.

2.5 LAND USES, SENSITIVE RECEPTORS, ECOSYSTEMS AND CULTURAL

RESOURCES
The Project Site is located at 10480 Finch Avenue in Cupertino and according to the City of Cupertino Zoning Map (April 2017) is zoned as R1-6 (single family residential).

Prior to the 2017 purchase of the Project Site by the District, the property had been owned by the Pestarino family since the 1930s. The property historically contained a prune tree orchard

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from at least 1939 through the late 1950s and the existing residential building is present in a 1956 aerial photograph. Additionally, the Project Site contains a workshop (wood- framed with corrugate metal roof) located at the southeast corner of the Project Site. Located south and adjacent to the workshop are two, small, single-room dwellings that are wood-framed and situated on concrete blocks. These dwellings were the original residential structures.

The Project Site is bordered to the north by Phil Lane, beyond which is residential property; to the east and south by Sedgwick Elementary School; to the west by residential property; and to the northwest by Finch Avenue, beyond which is residential property.

According to the Final Santa Clara Valley Habitat Plan dated August 2012, the Project Site is not located within an area of significant biological resource and no endangered or threatened species are found in the immediate vicinity of the Project Site . Additionally, no wetlands have been identified at the Project Site.

According to the Cupertino General Plan Community Vision 2015 – 2040 (October 2015) there are no historic sites located within the immediate vicinity of the project. There are several structures in the City of Cupertino including schools, churches, and residences that are identified as historic sites.

There is a potential that prehistoric and historic resources could be located below the surface and may be encountered during the course of future construction activities. In the event that any prehistoric or historic subsurface cultural resources are discovered during ground disturbing activities, an immediate evaluation of the find should be conducted by a qualified archaeologist (CEQA §15064.5 (f)).

2.6 METEOROLOGY
Cupertino is located at the southern end of the San Francisco Bay. The eastern part of the city, located in the Santa Clara Valley, is flat while the western part of the city slopes into the Santa Cruz Mountains . During the month of July the average low temperature is 54 degrees Fahrenheit (°F) and the average high temperature is 82 °F. During January the average low temperature is 39 °F and the average high temperature is 58 °F.

During the summer, there is a moderate flow of marine air through the lower passes of the mountains that frequently reach speeds of 20 miles per hour (mph) or more. The same pattern is also responsible for the light to moderate winds from the northwest that blow up the Santa Clara Valley on summer afternoons. In winter winds are predominantly southerly and are strongest at higher elevations. Precipitation averages only 16 inches in parts of the Santa Clara Valley, but over the mountains to the east it is as much as 30 inches.

2.7 PREVIOUS SITE ACTIONS

2.7.1 Phase I Environmental Site Assessment
Cornerstone Earth Group (Cornerstone), on behalf of David J. Powers & Associates, prepared the document titled Phase I Environmental Site Assessment and Preliminary Soil Quality Evaluation, 10480 Finch Avenue, Cupertino, California and dated July 1, 2014. B ase on the

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findings of the Phase I E nvironmental Site Assessment (E SA), Cornerstone identified the following recognized environmental conditions (RECs):
• Historic agricultural use;
• Lead in soil related to the weathering of lead-based paint (LBP); and • A former 500-gallon underground storage tank (UST) that was removed in 1996.

Based on the result so the soil sampling performed during UST removal activities, the Santa Clara Valley Water District (SCVWD) issued a case-closure letter for the UST dated March 26, 1997 stating that “Due to the low levels of hydrocarbons detected and the site location, Santa Clara Valley Water District staff believes that with time the residual pollution will naturally attenuate and d oes not require any further corrective action at this time.”
Since RECs were identified as part of the Phase I ESA, Cornerstone conducted preliminary soil assessment activities at the Project Site. Based on the historic agricultural use (orchard) at the Project Site and the age/construction of the existing structures, a total of sixteen surface soil samples were collected throughout the Project Site and chemically analyzed for the presence of pesticides, arsenic, lead, and mercury. Five of the soil samples were collected at the perimeter of the residence, and two soil samples were collected at the perimeter of the workshop.

Below is summary of the analytical results:
• Chlordane was reported at concentrations up to 2,800 micrograms per kilogram (ug/kg);
• Arsenic was reported at concentrations rangi ng from 5.2 m illigrams per kilogram (mg/kg) to 15 mg/kg; and
• Lead was reported at concentrations ranging from 9.0 mg/kg to 100 mg/kg.

Additionally, the soil assessment activities included the advancement of one drill hole using direct-push drilling technology to an approximate depth of 20 feet at the location of the former UST. Soil samples were collected from approximate depths of 8 feet and 12 feet, which were chemically analyzed for the presence of TPHg, benzene, toluene, ethylbenzene, total xylenes (BTEX) and methyl-tert butyl ether (MTBE). Reportedly, TPHg, BTEX, or MTBE concentrations were not identified in the soil sample collected from a depth of 8 feet below ground surface (bgs). However, TPHg, ethylbenzene, and total xylenes were identified at concentrations of 1,300 mg/kg, 27 mg/kg, and 180 mg/kg, respectively in the 12-foot soil sample.

2.7.2 Preliminary Environmental Assessment
A PEA was completed for the Project Site, and is documented in the Padre prepared report titled: Preliminary Environmental Assessment, Sedgwick Elementary School Expansion Project, 10480 Finch Avenue, Cupertino, Santa Clara County, California, September 15, 2015.

The results of the PEA screening level risk assessment estimated the total risk from COPCs identified in soils at the Project Site to be 3.2 x 10 -5, which provides an increased cancer
risk of greater than 1 in 1,000,000 (>10-6). The total health hazard from COPCs identified in soils at the Project Site is estimated to be 0.46, which does not provide an increased health hazard

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(i.e., >1). Therefore, a response action to reduce and/or eliminate the COPCs identified in surficial soils at the Project Site is recommended.

Lead concentrations ranged from 9.0 to 310 mg/kg in soil samples collected throughout the Project Site. Using DTSC’s lead risk assessment spreadsheet model (LeadSpread Version 8), exposure to the lead concentrations identified at the Project Site would result in a 90th percentile blood lead concentration of 8.0 micrograms per deciliter ( µg/dl) in children, which exceeds the Office of Environmental Health Hazard Assessment (OEHHA) blood toxicity level of 1 µg/dl. Therefore, a response action to reduce or eliminate lead-impacted soil is recommended.

Arsenic concentrations ranged from 5.2 to 15 mg/kg in soil samples collected from across the Project Site. The arsenic data set consisted of four soil samples collected as part of the PEA, and 16 soil samples previously collected as part of a preliminary soil evaluation completed by others (Cornerstone, 2014). The four PEA soil samples were collected as step -out and step - down samples at the location of soil sample SS-6, which reported the highest Project Site arsenic concentration at 15 mg/kg. Arsenic concentrations reported for the PEA soil samples ranged from

5.7 to 13 mg/kg, indicating that arsenic concentrations in soil at this location do not present a potential “hotspot” for arsenic in soil. A statistical evaluation was performed by calculating the 95% Upper Confidence Limit (UCL) for the arsenic data set. The 95% UCL for arsenic in soil at the Project Site was calculated to be 10 mg/kg. A graphical evaluation completed by creating a normal probability plot of the arsenic data set. The shape of the plotted data presents a relatively normal distribution. Therefore, arsenic concentrations identified in surface soil at the Project Site are representative of ambient concentrations and further assessment and/or remedial action for arsenic in soil is not warranted.

Results of the soil gas assessment conducted at the Project Site identified low level concentrations of VOCs; however, none of the o f the VOC s exceeded their respective human health screening levels. The results of the PEA screening level risk assessment for soil gas estimated the total risk to be 8.6 x 10
-9, which does not provide an increased cancer risk of greater than 1 in 1,000,000 (>10-6). The cumulative hazard was estimated to be 0.0003, which does not provide a significant health hazard (>1). Therefore, further assessment and/or remediation regarding VOCs identified in soil gas at the Project Site is not warranted.

Due to elevated concentrations of OCPs and lead identified in surface soil around existing structures at the Project Site, Padre recommended a response action to reduce or eliminate the potential impact of the se contaminants. The recommended remedial action is excavation, removal, and offsite disposal at an appropriate landfill. Prior to the response action, Padre recommended conducting a Supplemental Site Investigation (SSI) to further define chlordane and lead impacts around the structures.

DTSC approved the Final PEA report in a letter dated January 26, 2016. A copy of the Conceptual Site Model, data summary tables and associated plates from the PEA report is presented in Appendix C.

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2.7.3 Supplemental Site Investigation
An SSI was completed for the Project Site, and is documented in the Padre prepared report titled: Supplemental Site Investigation, Sedgwick Elementary School Expansion Project , 10480 Finch Avenue, Cupertino, Santa Clara County, California, January September 15, 2015.

The organochlorine pesticides chlordane, DDD, DDE, DDT, dieldrin, gamma -BHC (lindane), endrin heptachlor, heptachlor epoxide, and toxaphene were identified in surface soils at the Project Site. Using the highest concentration for each COC identified at the Project Site, the total risk index was estimated to be 3. 3 x 10-5, which provides an increased cancer risk of greater than 1 in 1,000,000 (>10-6). Chlordane is the predominant pesticide of concern with the impacted areas identified to be located at the north, west and southeast perimeters of the main residence structure.

Lead concentrations ranged from 9.0 mg/kg to 310 mg/kg in soil samples collected across the Project Site which exceeds DTSC’s screening level of 80 mg/kg. Using the 95% UCL (60 mg/kg), a risk assessment was performed using the DTSC lead risk assessment spreadsheet model (LeadSpread Version 8). Based on the LeadSpread output, exposure to the lead concentrations detected at the Project Site will result in a 90th percentile blood lead concentration of 0.8 µg/dl in children which is below OEHHA’s blood toxicity level of 1 µg/l. However, a further review of lead in soil data identifies a group of six soil samples located near the workshop/single- room dwelling with concentrations of lead ranging from 83 mg/kg to 310 mg/kg. Therefore, a response action to reduce or eliminate the lead-impacted soil along the west and southwest side of the workshop/single-room dwelling is recommended.

Due to elevated concentrations of COC identified in surface soil around existing structures located at the Project Site, Padre recommended further action to reduce or eliminate the potential impact of these contaminants. The recommended remedial action is excavation, transportation and off-site disposal at an appropriate landfill.

DTSC approved the Final SSI report in a letter dated January 8, 2016. A copy of the data summary tables and associated plates from the SSI report is presented in Appendix C.

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3.0 NATURE, SOURCE, AND EXTENT OF CONTAMINANTS

3.1 NATURE AND SOURCE OF CONTAMINANTS
The results of the PEA and SSI identified and confirmed the presence of chlordane and lead in soil at the Project Site requiring a response action. Chemical specific information is provided below:

CHLORDANE: Chlordane is a man-made chemical that was used as a pesticide in the United States from 1948 to 1988. From 1983 to 1988, chlordane’s only approved use was to control termites in homes. The pesticide was typically applied to the soil around the foundations of buildings with wood components.

LEAD: Lead is a heavy, low melting, bluish-gray metal that occurs naturally in the Earth's crust; however, it is rarely found naturally as a metal. It is usually found combined with two or more other elements to form lead compounds. Metallic lead is resistant to corrosion (i.e., not easily attacked by air or water). When exposed to air or water, thin films of lead compounds are formed that protect the metal from further attack. Lead is easily molded and shaped and can be combined with other metals to form alloys. Lead and lead alloys are commonly found in pipes, storage batteries, weights, shot and ammunition, cable covers, and sheets used to shield us from radiation. The largest use for lead is in storage batteries in cars and other vehicles. Lead compounds are used as a pigment in paints, dyes, and ceramic glazes and in caulk. The amount of lead used in these products has been reduced in recent years to minimize lead’s harmful effect on people and animals.

Tetraethyl lead and tetramethyl lead were once used in the United States as gasoline additives to increase octane rating. However, their use was phased out in the United States in the 1980s, and lead was banned for use in gasoline for motor vehicles beginning January 1, 1996. Lead used in ammunition, which is the largest non-battery end-use, has remained fairly constant in recent years. However, even the use of lead in bullets and shot as well as in fishing sinkers is being reduced because of its harm to the environment.

3.2 EXTENT AND VOLUME OF CONTAMINANTS
The extent and volume of soil impacted by COC s at concentrations exceeding their respective risk screening levels has been calculated to be approximately 300 cubic-yards (cy).

The areas of concern (AOC) requiring a response action are presented on Plate 3-1. The vertical extent of soil contamination extends to depths of approximately 2.0 feet. The AOC has been designated into three sub-areas described below:
• AOC – A: Residence (approx. 240 cy);
• A OC – B: Outbuildings (approx. 50 cy); and
• AOC – C: Grass area (approx. 10 cy).

When compacted soil is excavated and stockpiled, the compacted soil is loosened, and depending on soil types the volume of stockpiled soil may increase by 10% to 25% (expansion factor). Additionally, excavated soil is transported and disposed of by weight (i.e., tonnage). A

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rule of thumb for calculating dry weight for silty sand is to multiple the soil volume by 1.35 to obtain the soil amount in tons. Therefore, the calculated quantity of soil to be transported and disposed of at the appropriate landfill is calculated as follows:
• 300 cy (insitu) x 1.2 (expansion factor) x 1.35 (conversion factor) = 486 tons of soil.

The estimated total weight of soil to be transported and disposed of at the appropriate landfill facility is calculated to be approximately 486 tons. Transporting soil using a truck and trailer combination would allow for approximately 22 tons per load. Therefore, the calculated quantity of truck and trailer loads is calculated as follows:
• 486 tons divided by 22 tons per load = 22 truck and trailer loads.

The locations of the removal action areas at the Project Site are presented on Plate 3-1. Additional excavation at the location of the removal action area may be necessary, based on the results of confirmation soil sampling as discussed in Section 7.7.2.

3.3 HEALTH EFFECT OF CONTAMINANTS
The identified COC and their health effects are discussed below:

CHLORDANE: Technical grade chlordane is toxic to humans by ingestion of contaminated food, skin absorption, and inhalation. Occupational exposure by dermal and inhalation routes may be significant. Chlordane is easily absorbed through the skin. Technical grade chlordane is a stimulant to the central nervous system but its exact mode of action is unknown. The general symptoms are convulsions and tremors followed by depression.

Cycles of excitement and depression may be repeated several times. Other symptoms are liver damage, anorexia and weight loss. The U.S. EPA has determined that chlordane is a probable human carcinogen (B2 classification).

LEAD: The effects of lead are the same whether it enters the body through breathing or ingestion. The main target for lead toxicity is the nervous system, both in adults and children. Long-term exposure of adults to lead at work has resulted in dec reased performance in some tests that measure functions of the nervous system. Lead exposure may also cause weakness in fingers, wrists, or ankles. Lead exposure also causes small increases in blood pressure, particularly in middle-aged and older people. Lead exposure may also cause anemia. At high levels of exposure, lead can severely damage the brain and kidneys in adults or children and ultimately cause death. Children are more sensitive to the health effects of lead than adults. A child who swallows large amounts of lead may develop anemia, kidney damage, colic (severe "stomach ache"), muscle weakness, and brain damage. In some cases, the amount of lead in the child's body can be lowered by giving the child certain drugs that help eliminate lead from the body. If a child swallows smaller amounts of lead, such as dust containing lead from paint, much less severe but still important effects on blood, development, and behavior may occur. In this case, recovery is likely once the child is removed from the source of lead exposure. At still lower levels of exposure, lead can affect a child's mental and physical growth. There is no conclusive proof that lead causes cancer (is carcinogenic) in humans. The Department of Health and Human Services (DHHS) has determined that lead and lead compounds are reasonably anticipated

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to be human carcinogens based on limited evidence from studies in humans and sufficient evidence from animal studies, and the EPA has determined that lead is a probable human carcinogen. The International Agency for Research on Cancer (IARC) has determined that inorganic lead is probably carcinogenic to humans. IARC determined that organic lead compounds are not classifiable as to their carcinogenicity in humans based on inadequate evidence from studies in humans and in animals.

3.4 RECEPTORS POTENTIALLY AFFECTED BY THE SITE
A conceptual site model has been developed that identifies receptors that may be exposed to COC at the Project Site. The conceptual site model identifies the potential exposure pathways (i.e., ingestion of contaminated soils, inhalation of contaminated particulates, and dermal contact with contaminated soils) for the contaminated media at the Project Site. A copy of the Conceptual Site Model is presented in Appendix C.

RESIDENCE

WORKSHOP

SINGLE-ROOM

DWELLING

PROJECT SITE BOUNDARY
AOC - A (approx. 240 yd³)
AOC - B (approx. 50 yd³)
AOC - C (approx. 10 yd³)
associates, inc.

ENGINEERS, GEOLOGISTS &

ENVIRONMENTAL SCIENTISTS
PLATE 3-1
DR. BY
AC
APP. BYAREAS OF CONCERN
DATE
PROJECT NO.
7/28/17AJK 1601-3361

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4.0 RISK EVALUATION AND PRELIMINARY CLEANUP GOALS
This section presents detailed information regarding development of cleanup goals (CGs) for the COC identified at the Project Site.

4.1 RISK EVALUATION
The results of the PEA human health screening- level evaluation identified the following COC in soil at the Project Site:
• C hlordane; and
• Lead.

The DTSC-modified screening levels or the U.S. EPA RSLs (if DTSC-modified screening levels are not available) were used to conduct a screening -level human health risk assessment using the residential land- use scenario. Screening levels are used to evaluate carcinogenic (cancer causing) impacts and non- carcinogenic impacts (i.e., liver or kidney damage).

Carcinogenic screening levels are typically based on a predicted excess long-term cancer risk of one in a million (1.0E- 06), which is DTSC’s point of departure for managing risks. Non- carcinogenic screening levels are based on maintaining the daily COC intake below the level at which deleterious health effects are considered possible.

In accordance with PEA guidance documents and DTSC’s Human Health Risk Assessment (HHRA) Note 3 (revised August 2017) the maxi mum detected chemical concentrations in soil were evaluated as potential exposure point concentrations (EPCs). The EPCs were compared to their respective screening levels. The ratio of an EPC to the corresponding carcinogenic screening level was multiplied by 1E -06 to estimate the chemical specific screening cancer risk. For non -carcinogens, the chemical-specific hazard index is the ratio of the EPC to the screening level based on non- carcinogenic effects. The sums of the chemical-specific screening cancer risk and screening hazard index are the cumulative screening cancer risk and hazard index, respectively.

The total risk from OCPs identified in soils at the Project Site was estimated to be

3.3 x 10
-5, which provides an increased cancer risk of greater than 1 in 1,000,000 (>10-6). The total health hazard from OCPs identified in soils at the Project Site was estimated to be 0.46, which does not present an increased health hazard (i.e., > 1). Chlordane is the predominant pesticide of concern within the impacted areas which are identified to be located at the north, west and southeast perimeters of the main residence structure.

Lead concentrations in soil were compared to the OEHHA’s residential screening level of 80 mg/kg. This risk-based soil concentration developed in DTSC’s lead risk spreadsheet (LeadSpread 8) is based on the OEHHA incremental blood lead criterion. The value is meant to be implemented as an estimate of the EPC usually based on the 95 percent confidence limit on the arithmetic mean, not as a 'not to exceed' soil concentration.

Lead concentrations ranged from 9.0 mg/kg to 310 mg/kg in soil samples collected across the Project Site which exceeds DTSC’s screening level of 80 mg/kg. Using the 95% UCL (60 mg/kg), a risk assessment was performed using the DTSC lead risk assessment spreadsheet model (LeadSpread Version 8). Based on the LeadSpread output, exposure to the lead

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concentrations detected at the Project Site will result in a 90th percentile blood lead concentration of 0.8 µg/dl in children which is below OEHHA’s blood toxicity level of 1 µg/l. However, a further review of lead in soil data identifies a group of six soil samples located near the workshop/single- room dwelling with concentrations of lead ranging from 83 mg/kg to 310 mg/kg. Therefore, a response action to reduce or eliminate the lead-impacted soil along the west and southwest side of the workshop/single-room dwelling is recommended.

A comparison of the highest site concentration in soil for each COC to the appropriate screening level is presented in Table 4-1.

Table 4-1: Comparison to Screening Levels
COPC Highest Site Concentration
(mg/kg)
Screening Level
(mg/kg)
Chlordane 13 0.440 (a)
Lead 310 80 (b)
Notes:
mg/kg – milligrams per kilogram
(a) D TSC’s HHRA Note 3 (August 2017)
(b) OEHHA LeadSpread Version 8.

4.1.1 Environmental Screening Risk Evaluation
A detailed ecological screening evaluation was not performed as part of the PEA because the Project Site has been developed as a residential property since the 1950s. Natural wildlife areas were not noted at the Project Site during the course of the PEA. Therefore, based on the available information, there does not appear to be a significant pathway of exposure to nonhuman, sensitive ecological species.

4.2 VOLUNTARY CLEANUP AGREEMENT
Pursuant to Education Code section 17213.2(a), the District entered into a School Cleanup Agreement (Docket Number HSA- FY15/16-115) with DTSC on June 30, 2017. If the District is unable or unwilling to complete the response action as required, then DTSC will immediately notify the Office of Public School Construction and the California Department of Education.

4.3 CLEANUP GOALS
As discussed in Section 3.1, the identified COC in soil at the Project Site consist of chlordane and lead. RSLs are based on an excess cancer risk of one-in-a-million (10 -6) and/or a
hazard quotient of 1.0 for non- cancer health effects. These thresholds are conservative and responsive to the overall protection of human health and the environment. The cleanup goal for each COC is presented Table 4-2.

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Table 4-2: Cleanup Goals (CGs)
COC in Soil CGs
(mg/kg)
Chlordane 0.440 (a)
Lead 80 (b)
Notes:
mg/kg – milligrams per kilogram
(a) DTSC’s HHRA Note 3 (August 2017)
(b) OEHHA LeadSpread Version 8.

The cleanup goal will be considered achieved when the analytical results of confirmation soil samples collected from the excavation areas indicate that any residual concentrations of COC in soil are at or below their respective cleanup goal.

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5.0 ENGINEERING EVALUATION / COST ANALYSIS (EE/CA)
This Engineering Evaluation / Cost Analysis (EE/CA) was conducted for the proposed response action (RA) at the Project Site in accordance with the U .S. EPA g uidance titled “Guidance on Conducting Non-Time-Critical Removal Actions under CERCLA ( USEPA, 1993)”.

It was prepared as part of the RAW developed for the Project Site to aid in the evaluation of remediation alternatives for the mitigation of impacted soils at the Project Site.

The proposed RA at the Project Site has been determined to be a non- time-critical response, based on the risk evaluation and Project Site considerations. The proposed RA will be conducted in accordance with protocols of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) and the National Oil and Hazardous Substances Pollution Contingency Plan (NCP) codified in Part 300 of Code of Federal Regulations, Title 40 (40 CFR 300). Under 40 CFR 300.415 of the NCP, an EE/CA is required to address the implementability, effectiveness, and cost of a non-time-critical RA.

This EE/CA will be used as the basis for the planned non- time-critical RA. As the lead agency, DTSC has final authority of the selected alternatives and the overall public participation activities.

5.1 REMOVAL ACTION SCOPE
This RAW outlines the remedy for addressing the presence of COC in soil at the Project Site. Approximately 300 cy of impacted soil will require a removal action. T he goals and objectives of the proposed RA are presented in Section 1.1. The CGs for the identified COC are presented in Table 4-2, as described in Section 4.3.

5.2 IDENTIFICATION AND EVALUATION OF REMOVAL ACTION ALTERNATIVES The purpose of the removal action is to prevent, minimize, stabilize, mitigate, or eliminate the release or threat of release of a hazardous waste or substance at the Site. Based on historical patterns of remedy selection for sites where chlordane and lead are COC in soil the “No Action” alternative and three other common alternatives were identified. A screening process was then used to generally evaluate the applicability of options to treat or otherwise remediate the COC that drives risk at the Site, based on EE/CA evaluation criteria (effectiveness, implement ability, and relative cost) and DTSC’s project guidance (general scientific and engineering evaluation).

5.2.1 EE/CA Alternative Evaluation Criteria
The criteria listed below were used during this evaluation process.

Effectiveness
• Performance and reliability to eliminate or reduce the risk associated with the identified COC (in terms of toxicity, mobility, or volume) at the Project Site; • Overall protection of public health and the environment (threshold factor);

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• Compliance with applicable or relevant and appropriate requirements (ARARs) presented in Section 6.0 (threshold factor);
• Long- and short-term effectiveness (balancing factor); • Reduction of toxicity, mobility, or volume through treatment (balancing factor); and • Ability to meet the RAOs presented in Section 1.1 (threshold factor).

Implementability:
• Capability of the alternate with respect to administrative and technical feasibility to Project Site conditions, e.g., space limitations, equipment availability, resource availability, utility requirements, monitoring concerns, and operation and maintenance; • Ability of the alternate to meet applicable federal, state, and local regulations and permitting requirements; and
• Ability of the alternate to meet the project schedule and facility operations requirements.

Cost:
• Assess the relative cost of each alternate based on estimated capital cost for construction or initial implementation and ongoing operational and maintenance (O&M) costs.

5.2.2 Description and Comparative Analysis of Removal Action Alternatives A screening evaluation was conducted to assess removal technologies and process options for mitigating the impacted soil present at the Project Site. Based on the RAOs presented in Section 1.1, the following four (4) alternatives were identified and developed for the proposed RA at the Project Site
Most of the identified removal alternatives were considered for application at the Project Site but were screened out immediately without detailed evaluation. The screen-out decision was made based on past experience at other similar sites and on scientific consider ation and engineering judgment, which indicated that they would either be ineffective in achieving RAOs, inappropriate technologies for remediating the elevated COC, or could not be implemented in a cost-effective manner.

5.2.2.1 No Action
The “No Action” alternative does not meet the criteria of effectiveness. While the “No Action” alternative was not considered by DTSC, it was evaluated (as required under the NCP) as a baseline to which the relative benefits of the other alternatives could be compared.

5.2.2.2 Excavation and Offsite Disposal
Excavation and offsite disposal is a well -proven, readily available technology that is a common method for r emediating low volume contaminat ed properties. It is a relativ ely simple process, with positive results. Equipment and labor required for this alternative is readily available and commonly used for school construction activities.

Excavation involves the removal of soil containing elevated levels of identified COC .

Excavation includes using loaders, backhoes, large diameter augers, and/or other appropriate

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equipment. Excavation operations may generate fugitive dust emissions. Therefore, suppressant foam, water spray and other forms of vapor and dust control may be required during excavation, and workers may be required to use personal protective equipment to reduce exposure to the COC. The depth of excavations may be limited due to physical constraints associated with the Project Site. Sloping excavation sidewalls may result in increased volume of soil requiring excavation. Confirmation soil sampling and analysis will be conducted to verify that CGs are met at the excavation bottom and sidewalls. Excavation would be an effective means for removing impacted soil from the Project Site and would be used in conjunction with appropriate disposal options. Off-site disposal involves removing impacted soil from the Project Site and transportation to an appropriate off-site disposal facility. This would be an effective means of removing COC impacted soil from the Project Site and meeting the RAOs for soil. Estimated costs for implementing an excavation and off -site disposal of impacted soil is approximately $200,000 to $230,000.

5.2.2.3 Treatment
Bioremediation can be used to treat OCPs in soil. A bioremediation program can be developed using proprietary biotechnology with soil amendments to enhance and elevate indigenous bacterial colonies for the destruction of recalcitrant organic contaminants such OCPs in soil. The time to complete in-situ bioremediation activities for OCPs to acceptable levels (below CGs) is estimated to require approximately four to five months to complete. Additionally, if fill material is also required to replace excavated soil, then associated costs can be approximately half of the cost for the traditional method of excavation and offsite disposal. Estimated costs for implementing a bioremediation program for OCPs is approximately $ 400,000 to $4 50,000.

However, since this bioremediation method is not effective for lead in soil, it is not considered a feasible option for meeting the RAOs for impacted soil at the Project Site.

5.2.2.4 Engineering and Institutional Controls
Engineering controls (ECs) and institutional controls (ICs) can be used to reduce or eliminate potential exposure to COC in soil at the Project Site. ECs include development of a Capping System with paved areas, building foundations, and/or cleanfill material, in conjunction with the development of an operation and maintenance (O&M) plan. ICs primarily consist of land- use covenants and deed notices/restrictions that provide information or notifications that residual contamination may remain on a property and identifies associated ECs to restrict access and exposure to contamination. ECs and ICs generally include the creation of a land- use covenant (LUC), which sets forth and defines land -use limitations. LUCs are recorded in the county in which the land is located, and must continue in perpetuity unless modified or terminated in accordance with applicable law.

Estimated costs for preparation of a LUC are approximately $40,000 to $50,000, and O&M implementation costs are approximately $15,000 to $25,000 annually. In addition, environmental monitoring costs during construction activities would cost approximately $25,000 to $35,000. The planned demolition of the existing structures in preparation for new construction (structures, play fields) would result in significant soil disturbance and the potential for spreading contamination throughout the Project Site. Protecting workers from exposure to COC at the Project Site during demolition and construction activities would be problematic. Therefore, the establishment of ECs

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and ICs at the Project Site is not considered a feasible option for meeting the RAOs for impacted soil at the Project Site.

5.3 DESCRIPTION OF RECOMMENDED REMEDY
The recommended RA remedy, as deemed preferable by the District, co nsists of the excavation, transport, and off-site disposal of soil containing elevated concentrations of chlordane and lead at the Project Site. The activities that would be conducted to implement the RA activities are described below:
• Secure Project Site with chain-link fencing around property perimeter; • Demolition of building structures, while leaving building foundations in-place; • Excavation of approximately 300 cy of soil containing elevated concentrations of chlordane and lead at the Project Site.
• Stockpile excavated soil in quantities of approximately 150 cy per stockpile for waste characterization.
• C ollect confirmation soil samples from the excavation areas, and compare confirmation data to the CGs. If needed, excavate additional volume of soil until the CGs are met; • Select and obtain landfill approval for soil disposal; • Load, transport, and dispose of stockpiled soil to the appropriate disposal facility; and • Prepare removal action completion report (RACR).

5.4 COST ESTIMATE OF RECOMMENDED REMEDY
The recommended remedy is a removal action to prevent, minimize, stabilize, mitigate, or eliminate the release or threat of release of a hazardous waste or substance, costing approximately $192,500. A summary of the estimated cost for the removal action is outlined below:
• DTSC School Oversight Cost: $ 40,000.
• Preparation of a Removal Action Workplan (RAW): $ 15 ,000. • Pre-construction Activities: $ 5,000.
• Environmental Contractor (air monitoring, soil sampling, waste profiling): $ 35,000.
• Removal Contractor (excavation, stockpile, loading): $ 25,000. • Soil Transport and Disposal (50% Class I): $ 36,500. • Soil Transport and Disposal (50% Class II): $ 16,000. • Site Restoration: $ 5,000.
• Preparation of a Removal Action Completion Report: $ 15,000.

Total Cost Estimate: $ 192,500.

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6.0 APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS The removal action objectives must be consistent with Applicable or Relevant and Appropriate Requirements (ARARs) (40 CFR Section 300.415). The following definitions are derived from the National Oil and Hazardous Substances Pollution Contingency Plan (40 CFR Section 300.5).

Applicable Requirements : Are cleanup standards, standards of control, and other substantive environmental protection requirements, criteria, or limitations promulgated under Federal or State law that specifically address a hazardous substance, pollutant, contaminant, removal action, location, or other circumstance at a Site.

Relevant and Appropriate Requirements : Are cleanup standards, standards of control, and other substantive environmental protection requirements, criteria, or limitations promulgated under Federal or State law that, while not “applicable” to a hazardous substance, pollutant, contaminant, removal action, location, or other circumstance at a Site, address problems or situations sufficiently similar to those encountered at the Site that their use is well -suited to the particular Site.

ARARs typically are separated into three categories: 1) Chemical -specific ARARs; 2) Action-specific ARARs; and 3) Location-specific ARARs, and are described below:

Chemical-specific ARARs: These are usually health- or risk-based numerical values or methodologies which, when applied to site-specific conditions, result in the establishment of numerical values. These values establish the acceptable amount or concentration of a chemical that may be found in, or discharged to, the ambient environment.

Action-specific ARARs: These are usually technology- or activity-based requirements or limitations on actions taken with respect to hazardous wastes.

Location-specific ARARs: These are restrictions placed on the concentration of hazardous substances or the conduct of activities solely because they occur in special locations.

The potential ARARs for the Project Site’s COC and their selected remedy are presented below.

6.1 CHEMICAL-SPECIFIC ARARS

6.1.1 Risk Screening Levels
The U.S. EPA has developed risk screening levels (RSLs) for use in the human health risk screening process. Screening levels are used to evaluate carcinogenic (cancer causing) impacts and non-carcinogenic impacts (i.e., liver or kidney damage). Carcinogenic screening levels are typically based on a predicted excess long -term cancer risk of one in a million (1.0E -06). Non- carcinogenic screening levels are based on maintaining the daily COC intake below the level at which deleterious health effects are considered possible.

DTSC has developed modified screening levels for use in the human health risk screening process, and are presented in Human Health Risk Assessment (HHRA) Note 3, updated August 2017. The cleanup goal for each COC will be the respective RSL.

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6.1.2 Air Quality Management
The California Air Resources Board (ARB) and the U.S. EPA have adopted ambient (outdoor) air quality standards. These legal limits on ambient air pollution are designed to protect the health and welfare of Californians. The California Health and Safety Code Section 39606 provides the authority for the Bay Area Air Quality Management District (BAAQMD) to regulate ambient air pollution in the region of the Project Site. There are no BAAQMD permits required for the planned RA activities.

According to the BAAQMD the Project Site is exempt from the requirements of Regulation 8, Rule 40 because the soil is contaminated with non -volatile chemicals, and is unrelated to underground storage tank activities (8-40 Sections 113 and 115). As part of the “Notification Only Program”, the BAAQMD will be provided written notification of the planned excavation activities at least 5 days prior to the start of work.

On June 2, 2010, BAAQMD adopted Resolution 2010- 06, which sets forth California Environmental Quality Act (CEQA) thresholds of significance guidelines. The guidelines indicate that for construction-related projects such as the proposed response action, best management practices should be used to address fugitive dust. Best management practices for fugitive dust control are discussed in Sections 7.5 and 7.6 of this report. The guidelines also set forth emissions criteria for reactive organic gasses, oxides of nitrogen, particulate matter in exhaust (PM10, PM2.5) and local carbon monoxide. Based on the temporary construction period and the implementation of best management practices for construction emissions minimization, the planned removal action is not anticipated to result in the generation of significant quantities of these criteria air pollutants.

Dust control measures and monitoring activities will be implemented at the Project Site.

Measured total dust levels will be compared to site action levels. Site action levels are based on the Cal-OSHA permissible exposure levels (PELs) for each COC identified in soil at the Project Site. The PEL for total dust is 10 mg/m

3. Therefore, assuming that total dust is present at 10 mg/m3 in air and contains the maximum concentration of each COC identified at the Project Site, then site worker exposure levels can be calculated as follows:

Exposure Level (mg/m3) = soil concentration (mg/kg) x total dust PEL (mg/m3) 1,000,000 (mg/kg)
Where as, the dust exposure levels for each COC are as follows:

Chlordane: 0.00013 mg/m3 = 13 mg/kg x 10 mg/m3
1,000,000 mg/kg
Lead: 0.0031 mg/m3 = 310 mg/kg x 10 mg/m3
1,000,000 mg/kg

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Comparing the calculated dust exposure levels for each COC to their respective PEL shows that the selected air monitoring action level for the exclusion zone is protective of site worker health.

Calculated dust exposure levels are presented in Table 6-1.

Table 6-1: Dust Exposure Levels
Chemical of
Concern
Calculated Dust
Exposure Level(a)

CAL/OSHA PEL
Chlordane 0.00013 mg/m3 0.5 mg/m3
Lead 0.0031 mg/m3 0.05 mg/m3
Total Dust --- 10 mg/m3
Notes:

PEL - permissible exposure limit (8-hour, time-weighted average (TWA)). (a) – Calculated using 10 mg/m3 total dust.

6.1.3 Health and Safety Plan (HSP)
All contractors will be responsible for operating in accordance with the most current requirements of Title 8, California Code of Regulations, Section 5192 (8 CCR 5192) and Title 29, Code of Federal Regulations, Section 1910.120 (29 CFR 1910.120), Standards for Hazardous Waste Operations and Emergency Response (HAZWOPER). On-site personnel are responsible for operating in accordance with all applicable regulations of the Occupational Safety and Health Administration (OSHA) outlined in 8 CCR General Industry and Construction Safety Orders and 29 CFR 1910 and 29 CFR 1926, Construction Industry Standards, as well as other applicable federal, state and local laws and regulations. All personnel shall operate in compliance with all California OSHA requirements.

A site-specific health and safety plan ( HSP) has been prepared for the Project Site in accordance with current health and safety standards as specified by the federal and California OSHAs. A copy of the HSP is included as Appendix F.

The provisions of the HSP are mandatory for all personnel of the responsible party (R P) and its contractors who are at the Project Site. The RP’s contractor and its subcontractors doing fieldwork in association with this RAW will either adopt and abide by the HSP , or shall develop their own safety plans which, at a minimum, meet the requirements of the HSP. All onsite personnel shall read and sign the HSP prior to initiating activity at the Project Site.

6.2 ACTION-SPECIFIC ARARS

6.2.1 W aste Management
Excavated soil will be stockpiled onsite pending waste characterization. Based on the estimated volume of soil to be excavated (300 cy), the generated stockpiles will each contain

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approximately 150 cy of soil. Each stockpile will be labeled and sampled for waste characterization by collecting one 4-point composite soil sample from each stockpile, and chemically analyzed for the following constituents, or as required by the permitted waste disposal facility:
• OCPs (EPA Method 8081A); and
• CAM 17 Metals (EPA Method 6010/7000 series).

Waste classification and landfill approval will be obtained prior to transporting soil off the Project Site. If detected concentrations of COC do not exceed the California total threshold limit concentration (TTLC), then the soil will be disposed of as a non- hazardous waste. If detected concentrations of COC exceed the TTLC, then the soil will be classified as a hazardous waste.

The soil sample is then analyzed for the soluble threshold limit concentration (STLC) by the California Waste Extraction Test (WET) or the toxicity characteristic leaching procedure (TCLP), depending on the acceptance criteria of the landfill facility. If detected concentrations of COC exceed the STLC/TCLP then the soil will be classified as a RCRA-hazardous waste. The values for waste characterization are listed below:

Compound TTLC STLC TCLP
Chlordane 2.5 mg/kg 0.25 mg/L 0.03 mg/L
Lead 1,000 mg/kg 5.0 mg/L 5.0 mg/L
The District will then be required to obtain a California EPA temporary identification number for the disposal of the waste. Persons who generate, transport or offer to transport, treat, store, or dispose of hazardous waste generally must have an identification (ID) number, which is used to identify the hazardous waste handler and to track the waste from its point of origin to its final disposal (referred to as “cradle to grave”). Instructions on how to obtain a temporary ID number can be found at the DTSC website:
www.dtsc.ca.gov/IDManifest/index.cfm#identification(ID)Numbers .

Compliance with the DTSC requirements of hazardous waste generation, temporary onsite storage, transportation and disposal is required. Any container used for onsite storage will be properly labeled with a hazardous waste label. Within 90 days after its generation, the hazardous waste will be transported offsite for disposal. Any shipment of hazardous wastes in California will be transported by a registered hazardous waste hauler under a uniform hazardous waste manifest. Land ban requirements will also be followed as necessary.

6.2.2 C alifornia Environmental Quality Act (CEQA)
The California Environmental Quality Act (CEQA) is a statute that requires State and local agencies to identify the significant environmental impacts of their actions and to avoid or mitigate those impacts, if feasible. In response to the passage of the National Environmental Policy Act (NEPA) in 1969, the California Legislature passed the CEQA in 1970 as a system of checks and balances for land use development and management decisions in California. CEQA was subsequently codified into the Public Resources Code (division 13, section 21000 et seq.). The Resources Agency adopts and certifies certain regulations (known as CEQA Guidelines) to

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explain and interpret the CEQA law. These regulations were codified into the California Code of Regulations (CCR), title 14, chapter 3, section 15000 et seq.

CEQA is a self-executing statute with administrative procedures to ensure comprehensive environmental impact review prior to project approval. The Resources Agency does not enforce CEQA, nor does it review governmental actions for CEQA compliance. If necessary, the public may challenge a CEQA project decision in court. Where a State agency is the lead agency or a responsible/trustee agency, or where the project has statewide, regional, or area wide significance, such CEQA d ocuments are required to be submitted to the State Clearinghouse within the Governor’s Office of Planning and Research for processing State agency review.

A CEQA project is defined as a California project that has a potential for resulting in a direct physical change in the environment or a reasonably foreseeable indirect physical change in the environment. CEQA applies to discretionary CEQA projects proposed to be carried out or approved by California public agencies, unless an exemption applies. Onc e an activity is determined as a CEQA project, the lead agency conduct s a preliminary review to determine whether the project is exempt from CEQA. When the lead agency approves or determines to carry out a CEQA-exempt project, the agency may file a Notice of Exemption (NOE).

NOE is a brief notice which may be filed by an agency after it has decided to carry out or approve a project and has determined that the project is exempt from CEQA as being a certified State regulatory program activity, statutory exem ption, categorical exemption, or general rule exemption. While filing of a signed NOE with the State Clearinghouse (SCH) or a County Clerk, as appropriate, for an approved project by the lead agency or project proponent is generally not required, filing for certain housing projects approved or carried out by a local agency is mandatory.

The statute of limitation period for legal challenges to the agency’s exemption decision is 35 days with a filed NOE and 180 days without a filled NOE.

The proposed RA at the Project Site is a CEQA project with DTSC as the lead agency.

Two primary CEQA exemptions available for DTSC RAW -approval actions are: Class 30 Categorical Exemption, as specified in California Code of Regulations, Title 14, section 15330 (14 CCR 15330); and General Rule Exemption, as specified in California Code of Regulations, title 14, section 15061(b)(3) (14 CCR 15061).

Exemption Status: (Select one that is applicable)
☒ a. Class 30 Categorical Exemption as specified in 14 CCR 15330 ☐ b. General Rule Exemption, as specified in 14 CCR 15061 Reasons Why Project is CEQA-Exempt: (Select all that are applicable and add reference, source or section number to support each selected reason) ☒ a. Special Qualifications of Class 30 Categorical Exemption (14 CCR 15330): (Select all that are applicable)
☐ (1) The project is a minor cleanup action to be taken to prevent, minimize, stabilize, mitigate or eliminate the release or threat of release of a hazardous waste or hazardous substance. The estimated project cost is $200,000 which falls well below the cost criteria of $1 million. The

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estimated cost includes costs for preparation, approval and implementation of the RAW; implementation of an approved operation and maintenance plan (if applicable); administration of a land use covenant (if applicable), and DTSC oversight. (See Sections 5.3 and 5.4) ☐ (2) The project is consistent with applicable state and local environmental permitting requirements including, but not limited to, (Select all that are applicable)
☒ (a) offsite disposal (See Section 7.8);
☐ (b) air quality rules such as those governing vo latile organic compounds (VOCs);
☒ (c) water quality standards, e.g., waste discharge
requirements or storm water discharge requirements by the State Water Resources Control Board (SWRCB)or an
appropriate Regional Water Quality Control Board (RWQCB) (See Section 6.4); and
☐ (d) (Type in site-specific situations) (not applicable) and approved by the regulatory body with jurisdiction
over the site.
☒ (3) The project will not require the onsite use of a hazardous waste incinerator or thermal treatment unit. (See Section 5.3) ☒ (4) The project will not require the relocation of residences or businesses. (See Sections 5.3 and 7.2.4)
☒ (5) The project will not involve the potential release into the air of volatile organic compounds (VOCs) as defined in Health and Safety Code section 25123.6, except for small scale in situ soil vapor extraction and treatment systems which have been permitted by the local Air Pollution Control District (APCD) or Air Quality Management District (AQMD). (See Section

6.3)
☐ b. General Exceptions to Categorical Exemptions of All Classes (14 CCR 15300.2):
(Select all that are applicable)
☐ (1) The cumulative impact of successive projects of the same type on the same place, over time is not significant. (See Section 5.3) ☐ (2) There is no reasonable possibility that the activity will have a significant effect on the environment due to unusual circumstances, because of the relatively small volume (approximately ___ CY), low level of work activity (minor excavation and disposal), short project duration (approximately five working days), and control measures associated with excavation and off-site disposal of the impacted soils at the Project Site. (See Section 5.3)
☐ (3) There is no possibility that the project may result in damage to scenic resources within a designated State scenic highway.

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☐ (4) The project is not located on a site which is included on any list compiled pursuant to Government Code section 65962.5. (See Sec tion

2.1.3, Cortese List)
☐ (5) The project will not cause a substantial adverse change in t h e significance of a historical resource. (See Section 2.5) ☐ c. The Project Site is not in an area of biological or cultural resource significance. (See Sections 2.5, 7.2.5 and 7.2.6)
☐ d. The RAW has been prepared to support the decision for a LUC at the Project Site.

The LUC will restrict land uses of the Project Site to school operations and related day care center activities only and prohibit use of the Project Site as a residence, hospital, or other similar sensitive land use. The LUC will also require O&M activities of annual inspection and reporting for DTSC’s oversight, to ensure the in tegrity and long-term protectiveness of the LUC. This LUC removal action will not have a significant effect on the environment because the LUC will not result in any physical activities at the Project Site.
☐ e. As required by California Code of Regulations, title 22, division 39, section 67391.1(b), the RAW clearly (1) specifies that the limitations or controls will be incorporated into an appropriate land use covenant; and (2) includes a description of the implementation and enforcement provisions, including, but not limited to, frequency of owner inspections, frequency of DTSC inspections, owner reporting requirements; necessary to ensure the integrity and long-term protectiveness of the land use covenant. ☐ f. The project is not subject to CEQA because it can be seen w ith certainty that there is no possibility that the proje ct may have a significant effec t on the environment, because of the relatively small volume (approximately ___ CY), low level of work activity (minor excavation and disposal), short project duration (approx imately five working days), and control measures associated with excavation and off- site disposal of the impacted soils at the Site. The project is covered by the General Rule that CEQA applies only to projects which have the potential for causing a signifi cant effect on the environment.

As a result, it has been preliminarily determined that this cle anup action is a Class 30 Action, to be taken to minimize, mitigate, or eliminate the release or threat of release of a hazardous waste or substance.

As part of its approval process for the project, DTSC has prepared a Draft Notice of Exemption. Upon approval of this RAW, DTSC will file the NOE w ith the Governor’s Office of Planning and Research (OPR). A copy of the DTSC NOE is presented in Appendix D.

6.2.3 Stormwater Discharge
The State Water Resources Control Board (SWRCB), as part of the National Pollutant Discharge Elimination System (NPDES), has adopted a statewide NPDES General Permit for Stormwater Discharges Associated with Construction Activity to address discharges of storm water runoff from construction projects that encompass one acre or more in total acreage of soil

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disturbances. Construction activities subject to the General Permit include demolition, clearin g, grading, excavation, soil stockpiling, material storing, on -site staging, off-site staging, and other land disturbance activities (State Water Resources Control Board Order No.2009-0009-DWQ [as amended by Order No. 2010- 0014-DWQ], National Pollutant Discharge Elimination System, General Permit No.CAS000002).

To obtain coverage under the General Permit, dischargers are required to electronically submit the Permit Registration Documents (PRDs), which includes a Notice of Intent, Storm Water Pollution Prevention Plan (SWPPP), and SWPPP Compliance Checklist, and mail the appropriate permit fee to the SWRCB. The SWPPP is required to specify Best Management Practices (BMPs) to prevent all construction pollutants from contacting storm water and with the intent of keeping all products of erosion from moving offsite into receiving waters. The discharger is required to obtain coverage under the General Permit prior to commencement of construction activ ities.

When construction is complete or ownership has been transferred, the discharger is required to file a Notice of Termination with the appropriate California Regional Water Quality Control Board certifying that all State and local requirements have been met in accordance with the General Permit.

The total acreage of the areas to be disturbed during the removal action is approximately

0.08 acres. Therefore, an NPDES General Permit is not required for this RA.

Although a SWPPP is not required for this project, best management practices (BMPS) will be implemented to reduce or eliminate sediment and other pollutants from entering existing storm water drains located in adjacent streets. Depending on weather conditions at the time of removal action activities, the following BMPs will be implemented as appropriate:
• Control of runoff from stockpiled soil by covering each pile with plastic sheeting and surrounding the stockpile with silt fencing and/or filter roll barriers; • Temporary perimeter controls with silt fencing and/or filter roll barriers; • Protection of storm drain inlets with filter fabric and sand/gravel bag barriers; • Stabilized construction entrance/exit with truck tracking controls; and • Post construction erosion control measures (i.e., landscape and/or hardscape ground cover).

6.2.4 Q uality Assurance Project Plan (QAPP)
Quality assurance/quality control measures that will be used during project execution are documented in the QAPP included as Appendix G. The QAPP will assure that Project Site field and analytical data collected meet project Data Quality Objectives (DQOs) and RAOs to support decisions for utilization of the Project Site as an elementary school site.

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6.2.5 Others
All necessary permits (State, County, and/or City) and approvals identified in this RAW will be obtained prior to any removal activities. Upon approval from DTSC, removal activities will be performed by a California certified contractor with oversight from a California- licensed professional geologist and/or civil engineer.

According to Education Code section 17213.2 (e), if a previously unidentified environmental concern is discovered at any time during the removal action and/or school construction process, the school district shall cease all construction activities at the Project Site, notify DTSC, and take the necessary response actions as required by DTSC.

6.3 LOCATION-SPECIFIC ARARS

6.3.1 P ublic Participation
DTSC has developed a public participation strategy to determine the level of public interest in the proposed RA and ensure that the local community is informed of the proposed RA at the Project Site. Through the planned community survey, community interviews and/or other public participation activities, DTSC will provide the community with opportunities to be involved in DTSC’s decision-making process for the Project Site.

Based on expressed community interest or other factors, DTSC will hold a public comment period to accept comments on the proposed RA and, if appropriate (e.g., when there is high interest in the Site), a public meeting(s) to brief interested parties locally about the proposed RA during the public comment period, before approving the RAW. When a public comment period is planned, DTSC will determine its appropriate duration (0 to 30+ days). In general, DTSC will hold a 30-day public comment period. A responsiveness summary, including DTSC’s response to all public comments received, will be found in Appendix E of the Final RAW, and placed in the information repositories for public viewing.

6.3.1.1 Community Assessment
As part of the public participation process for the PEA report, the District issued a public notice of the planned public review period and public hearing on November 27 and December 4, 2015. The public notice was published in the San Jose Post - Record. The PEA report was made available for public review from November 30, 2015 through December 31, 2015 at both the Cupertino Union School District Office and the Operations Center. Additional copies were placed at the Cupertino Public Library. The public notice was presented at the school board meeting held on December 15, 2015. No written or verbal comments were received.

A community assessment will be conducted through a baseline community survey and/or interviews of nearby community members (including contiguous property owners, residents, business owners, elected/local officials, DTSC mandatory mail list and other affected/interested parties). Pending the results of community feedback regarding the RAW, the compiled community concerns will be addressed in a Community Profile Report (described in Section 6.3.1.2) and a Community Update (described in Section 6.3.1.3) for the Project Site.

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Depending on community interest, as reflected in the community assessment conducted for the Project Site, a public meeting may be planned in conjunction with a 30-day comment period for the RAW. The length of the comment period and the decision to have a public meeting will be modified as appropriate.

6.3.1.2 Community Profile Report
The DTSC will prepare the Community Profile Report (CPR) . The CPR is based on the information from a variety of sources including file review, s ite visits, demographic data, community interest/concerns (including interest from elected or local officials) shown during the public comment period and public hearing held by the District on the PEA for the Project Site, similar or relevant community interest/concerns shown during previous public participation activities for other DTSC projects within the surrounding community, and likely or existing level of community interest/concerns identified for the Project Site through the community survey or interviews. A copy of the CPR is presented in Appendix E. If a copy of the CPR is not available by the time of the submittal of the revised Draft RAW, then a copy of the CPR will be made available in the information repositories along with the Draft RAW.

6.3.1.3 Public Participation Activities
A public notice in the languages appropriate to the community will be published in local newspapers and posted at the Project Site. This notice will inform the community of the proposed soil cleanup RA at the Project Site and the availability of the Administrative Record file for public inspection during office hours at the Central Information Repository (in the DTSC regional office) and a temporarily established Information Repository (e.g., a local library or the school district office) listed below. Co pies of documents pertinent to this RAW (e.g., reports of previous site assessments and investigations, this RAW, and related DTSC determination letters for the Project Site) will be placed in the following Information Repositories:
• Cupertino Union School District, District Office
1309 South Mary Avenue, Suite #150, Sunnyvale, California 94087 Contact: Travis Kirk, Director – Facility Modernization (408) 252-3000
Open: 8am – 5:00pm (M-F)
• Department of Toxic Substances Control, Regional Records Office 8800 Cal Center Drive, Sacramento, California 95826-3200 Contact: Bobbi Jensen (916) 255-3779
Open: 9am – 5pm (M-Th); By Appointment Only
• Cupertino Public Library
10800 Torre Avenue, Cupertino, California 95014
Contact: Branch Manager (408) 446-1677
Open: 10am – 9 pm (Mon. - Thur.); 10am – 6pm (Fri. and Sat.); and 12pm – 6pm (Sun).

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• DTSC – Envirostor, www.envirostor.dtsc.ca.gov/public. At the webpage search bar, type in Sedgewick. The “Sites/Facilities” information will appear. Click on “View Information”, the summary page for “Sedgewick Elementary School Expansion Project” will appear. Click on “Site Facility Docs”, where you can access project related documents.

A Community Update has been prepared to provide information about the Project Site and the proposed response actions, including information concerning history, levels of contaminants found, possible health effects from contaminant exposures, proposed RA activities, prec autions to minimize worker exposure, controls to reduce dust, truck route for offsite disposal of excavated materials, public participation activities, and contact information. This Community Update will be circulated to a project mailing list that includes residents and businesses within a quarter of a mile of the Project Site, elected officials, special interest groups and DTSC’s priority mailing list . A copy of the DTSC Community Update is presented in Appendix F. If a copy of the Community Update is not available by the time of the submittal of the revised draft RAW, then a copy will be made available in the information repositories along with the draft RAW.

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7.0 REMOVAL ACTION IMPLEMENTATION
Data from the Project Site PEA indicated the presence of COC in soil at concentrations exceeding risk screening levels. Site -specific CGs have been established for this RA and are presented in Section 4.3. An EE/CA for the removal is included in Section 5.0. The most effective removal action option has been determined to be the excavation, transport, and off-site disposal of soil containing elevated levels of identified COC.

Removal activities will be performed by a California-licensed contractor, with supervision of a California -licensed professional geologist and/or civil engineer. Information regarding the roles and responsibilities of environmental consultants and removal contractors as they relate to the response action is provided on Plate 7-1.

All removal, transportation, and disposal of soil will be performed in accordance with all applicable federal, State, and local laws, regulations, ordinances and requirements. Field operations shall follow the suggested operational guidelines to prevent cross -media transfer of contaminants, as specified in "Best Management Practices (BMP) for Soils Treatment Technologies" (U.S. EPA 530-R-97-007).

7.1 FIELD DOCUMENTATION
The RA contractor will be responsible for maintaining a field logbook during the course of the RA activities. The field logbook will serve to document observations, personnel onsite, equipment arrival and departure times, and other vital project information.

7.1.1 Field Logbooks
Field logbooks will document where, when, how, and from whom any vital project information was obtained. Logbook entries will be complete and accurate enough to permit reconstruction of field activities. Logbooks will be bound with consecutively numbered pages .

Each page will be dated and the time of entry noted in military time. All entries will be legible, written in ink, and signed by the individual making the entries. Language will be factual, objective, and free of personal opinions or other terminology, which might prove inappropriate. If an error is made, corrections will be made by crossing a line through the error and entering the correct information. Corrections will be dated and initialed. No entries will be obliterated, erased, or rendered unreadable.

Entries in the field logbook will include the following for each fieldwork date:
• Project Site name and address
• Recorder’s name
• Team members and their responsibilities
• Time of arrival/entry on Project Site and time of departure • Other personnel onsite
• A summary of any onsite meetings
• Quantity of impacted soils (in terms of RCRA hazardous wastes, non- RCRA hazardous waste, and non-hazardous wastes) excavated

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• Quantity of impacted soils (in terms of RCRA hazardous wastes, non- RCRA hazardous waste, and non-hazardous wastes) temporarily stored onsite • Quantity of excavated soils in truckloads (in terms of RCRA hazardous wastes, non-RCRA hazardous waste, and non-hazardous wastes) transported offsite • Names of waste transporters and proposed disposal facilities • Copies or numbers of manifests or other shipping documents (such as bill of lading and weight tickets) for waste shipments
• Quantity of import fill material in truckloads
• Deviations from this RAW and HSP
• Changes in personnel and responsibilities as well as reasons for the changes • Levels of safety protection
• Calibration readings and equipment model for any equipment used The following information will be recorded during the collection of each sample:
• Sample identification number
• Sample location and description
• Site sketch showing sample location and measured distances • Sampler’s name(s)
• Date and time of sample collection
• Designation of sample as composite or grab
• Type of sample (i.e., matrix)
• Type of preservation
• Type of sampling equipment used
• Field observations and details important to analysis or integrity of samples (e.g., heavy rains, odors, colors, etc.)
• Chain-of-custody form numbers and chain-of-custody seal numbers • Transport arrangements (courier delivery, lab pickup, etc.) • Recipient laboratory

7.1.2 Chain-of-Custody Records
Chain-of-custody records are used to document sample collection and shipment to laboratory for possible chemical analyses. All sample shipments for analyses will be accompanied by a chain-of-custody record. Form(s) will be completed and sent with the samples for each laboratory and each shipment. If multiple coolers are sent to a single laboratory on a single day, chain-of-custody form(s) will be completed and sent with the samples for each cooler.

The chain-of-custody record will identify the contents of each shipment and maintain the custodial integrity of the samples. Generally, a sample is considered to be in someone’s custody if it is either in someone’s physical possession, in someone’s view, locked up, or kept in a secured area that is restricted to authorized personnel. Until receipt by the laboratory, the custody of the samples will be the responsibility of the sample collector. See the QAPP for more detailed information (Appendix G).

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The shipping containers in which samples are stored (usually sturdy cooler or ice chest) will also be sealed with self -adhesive custody seals any time they are not in someone’s possession or view before shipping. All custody seals will be signed and dated.

7.1.3 Photographs
Photographs will be taken of the excavation area(s), confirmation sample collection locations, and other areas of interest at the Project Site to document the RA. The photographs will serve to verify information entered in the field logbook. When a photograph is taken, the following information will be recorded in the logbook or will be recorded in a separate field photography log:
• Time, date, location, and, if appropriate, weather conditions; • Description of the subject photographed; and
• Name of person taking the photograph.

7.2 SITE PREPARATION AND SECURITY MEASURES
Prior to mobilization for the proposed RA, site preparation activities may include Project Site inspections, surveying, boundary staking, sampling, demarcation of hot spots, improvement of access roads, utility connections or disconnections, and fencing installation.

7.2.1 Delineation of AOCs
The areal limits of the AOCs will be delineated by the RA consultant prior to the commencement of removal activities by the RA contractor. The delineation of the AOCs is based on the results of the PEA . The AOCs are identified as the Exclusion Zone and will be distinguishable in field by signage, barricades, fencing, staking, flagging, and/or non- toxic high visibility paint.

7.2.2 Utility Clearance
Clearance of r emaining utilities and other hazardous underground obstacles will be conducted prior to initiating any soil excavation activities. Such possible obstacles may include water, electrical, gas, oil, communication cable, phone cable, TV cable, and sewer lines . At a minimum, the utility clearance will include a 48-hour notification of the local Underground Services Alert (USA).

7.2.3 Security Measures
Appropriate barriers and dust/privacy fencing will be installed prior to beginning the excavation process to ensure that all work areas are secure and safe. To ensure trespassers or unauthorized personnel are not allowed near work areas, security measures will include, but are not limited to:
• Posting notices directing visitors to the manager of the Site. • Maintaining a visitor’s log. Visitors shall have prior approval from the Site manager to enter the Site. Visitors shall not be permitted to enter the Site without first receiving site-specific health and safety information from the Site safety coordinator. • Installing barrier fencing to restrict access to sensitive areas such as exclusion zones.

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• Providing adequate Site security to ensure unauthorized personnel have no access to work areas and/or impacted materials.
• Before leaving the Site, all personnel must sign out in the visitor’s log. • Maintaining a safe and secure work area, including areas where equipment is stored or placed, at the close of each workday.
• Equipping all Site access gates with locking devices that will be locked during non-operation activities.
• Limiting access to the Site to authorized personnel only.

Persons requesting site access will be required to demonstrate a valid purpose for access and if access to work areas and/or impacted materials is planned, provide appropriate documentation to demonstrate they have received proper training required by the site- specific HSP (see Appendix F).

7.2.4 Contaminant Control
To prevent any potential exposure of material to the adjacent properties, the following measures will be implemented during the course of soil excavation activities:
• The RA will be conducted when the RAW is approved by DTSC. • The RP will take necessary steps to minimize impact to the community. Because air monitoring procedures (see Section 7.5) will be implemented during excavation activities, the covering of windows and doors at the nearby residences and/or commercial businesses is not warranted or anticipated. RA activities will not be conducted during the un-favored hours reasonably raised by the community concerns. Community members will be informed prior to initiation of any removal activities.

7.2.5 Cultural Resources Consideration
The Project Site is not located with an area of identified cultural resources significance (see Section 2.5). However, p rior to excavation, all contractors and subcontractors will be informed of the potential for discovering important paleontological, prehistorical, or historical resources below the ground surface and the legal consequences for damaging or destroying such resources. If any such resources are found, then all field activities shall halt within the area in question and a qualified paleontological or cultural resources specialist shall evaluate the situations and make recommendations for further action.

In the event of discovery or recognition of any human remains at the Project Site, there will be no further excavation or disturbance of the area in question or any nearby area reasonably suspected to overlie adjacent human remains until:
• The County Coroner has been informed and has determined that no investigation of the cause of death is required, and
• If the remains are of Native American origin, then the descendants from the deceased Native Americans will be required to make a recommendation to the landowner or the person responsible for the excavation work, for means of treating or disposing of, with appropriate dignity, the human remains and any associated grave goods as provided in Public Resources Code section 5097.98, or

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• The Native American Heritage Commission was unable to identify a descendant or the descendant failed to make a recommendation within 24 hours after being notified by the Commission.

7.2.6 Biological Resources Consideration
The Project Site is not in an area of biological resources significance (see Section 2.5).

7.2.7 Noise Control
Noise-generating construction operations will be limited to between the hours of 8am to 5pm, Monday through Friday. There shall be no start -up of machines or equipment before 7:30am, and there shall be no cleaning or servicing of machines or equipment past 6:00pm.

Construction activities will be prohibited on Saturdays, Sundays and federal holidays.

Construction equipment will be properly maintained and equipped with noise reduction intake and exhaust mufflers and engine shrouds, in accordance with manufacturers ’ recommendations.

Equipment engine shrouds will be closed during equipment operation. When not in use, motorized construction equipment will not be left idling. Trucks waiting in the on-site staging area to be loaded with soil for off -site transport, will not sit idling for more than five minutes. If this is the case the driver will immediately shut down the engine until it is ready to be loaded.

7.2.8 Permits and Plans
As discussed in Section 6.8, all necessary permits or approvals will be obtained prior to the implementation of the RA.

7.3 WORK ZONES
The field activities will be divided into three work zones 1) exclusion zone; 2) decontamination zone; and 3) support zone/staging area. The work zones for the RA are illustrated on Plate 7-2. The general elements of each of these work zones are described below:

7.3.1 Exclusion Zone
The exclusion zone includes the excavation areas; soil stockpiling areas; and soil loading areas for hauling off -site. The exclusion zone will be clearly identified in the field with a combination of caution tape, tem porary fencings and/or barricades. Only authorized personnel will be allowed to enter the exclusion zone.

7.3.2 Decontamination Zone
A decontamination zone will be established at the Project Site. The decontamination zone is where soil, debris, and dust will be removed from equipment, transportation vehicles, and personnel leaving the exclusion zone. Decontamination of equipment and vehicles may consist of brushing and/or high pressure washing depending on weather conditions during the removal action. Deconta mination of personnel may include the removal and disposal of personnel protection equipment (i.e. tyvek suites, rubber gloves, etc.).

7.3.3 Support Zone / Staging Area
A support zone / staging area will be established to provide for administrative and support functions (command post, first aid station, rest area, etc.) necessary to keep the field activ ities

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operating smoothly. The RA contractor shall provide potable water and wash facilities for the field personnel in this location.

7.4 EXCAVATION
The excavation program will consist of excavating, stockpiling, and transporting for off-site disposal of approximately 300 cy of soil containing elevated levels of identified COC s. The completed excavations will be sampled to confirm that the removal action has met the DTSC approved cleanup goals (Section 4.3). The soil stockpiles will be sampled and profiled for waste classification and approval for disposal at an appropriate landfill facility. The soil stockpile s will then be loaded into truck and trailer combinations for transported to the approved facility. The excavation areas and soil stockpile areas will be fenced -off and will contain the appropriate signage to prevent any pedestrian and/or site visitor traffic from entering. During off -work hours the entrance to the Project Site will be locked. Work zones are presented on Plate 7-2, and the excavation plan is presented on Plate 7-3.

Soil excavation activities will be performed by a licensed hazardous materials contractor and personnel with training in hazardous waste operations (40 -hour OSHA Training and up to date 8 -hour OSHA Refresher Training). In addition, California OSHA’s Construction Safety Orders (especially 8 CCR 1539 and 1541) will be followed, as appropriate.

7.4.1 Trenching, Excavation, and Confined Space Entry
Occupational Safety and Health Administration (OSHA) standards require safe access and egress to all excavations, including ladders, steps, ramps, or other safe means of exit for employees working in trench excavations 4-feet or deeper. Trenches 5 -feet deep or greater require a protective system. If less than 5 -feet deep, a competent person may determine that a protective system (benching, sloping, shoring or shielding) is not required.

Confined space is a space that, by design and/or configuration, has limited openings for entry and exit, unfavorable natural ventilation, may contain or produce hazardous substances, and is not intended for continuous employee occupancy.

The estimated depth of planned excavations at the Project Site is approximately 2 to 2.5- feet. Therefore, the need for a protective system and/or confined space entry requirements are not anticipated. If confined space entry is needed, work will stop and the health and safety plan will be revised to address this development.

7.4.2 Soil Staging and Storage Operations
Soil will be staged near the south central portion of the Project Site. Based on the estimated volume of soil to be excavated (300 cy), the generated stockpiles will each contain approximately 150 cy of soil. . During non-excavation hours, the excavated soil stockpile will be covered with plastic sheeting to prevent dust generation and/or run -off during rain events.

Additional field applications may involve installation of other physical barrier s that minimize the movement of materials from the Project Site by wind, water, or any other mechanism. .

The temporary onsite storage of excavated soil will be secured and properly labeled until offsite transportation and disposal are ready for loading. In no case, will the waste storage be

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longer than 90 days after its generation. Storage of any hazardous waste longer than 90 days after its generation may require a permit or approval from DTSC.

7.4.3 Waste Segregation Operations
Each soil stockpile will be labeled and sampled for waste characterization and classification per the requirements of the waste disposal facility. One four-point composite soil sample will be collected from each stockpile and submitted to the analytical laboratory to be chemically analyzed for OCPs and CAM 17 metals, or as required by the permitted waste disposal facility.

7.4.4 Decontamination Procedures
Excavation equipment, transportation vehicles, and personnel leaving the exclusion zone will enter the decontamination zone. The decontamination zone will be used to remove soil, debris, and dust from equipment, transportation vehicles, and personnel prior to leaving the work zones. The decontamination of equipment and transportation vehicles includes dry and wet methods. Dry methods are the primary means of decontamination and consist of brushing and scraping to remove soil, debris, and dust. If dry methods are not effective, wet methods may be used such as steam cleaning and/or pressure washing. Washtubs with soap and water and rinse tubs will be provided for the cleaning of re-useable hand-held equipment.

Decontamination of personnel may include the removal and disposal of PPE (i.e. tyvek suites, rubber gloves, etc.). Disposable equipment intended for one time use will be package for proper disposal.

Prior to leaving the Project Site all truck loads will be inspected to ensure that the exterior of trucks are clean and clear of excess soil and debris, and that each truck load is properly covered. Each truck load will maintain the necessary documents for transport and disposal of the waste. A documentation of each truckload will be recorded in the field logbook, which will be maintained for the duration of the removal action activities.

7.4.5 Excavation Plan
The excavation plan has been designated into three areas of concern (AOCs) identified as follows:
• AOC – A: Residence (approx. 240 cy);
• AOC – B: Outbuildings (approx. 50 cy); and
• AOC – C: Grass area (approx. 10 cy).

The total depth of each AOC is approximately 2.0-feet, resulting in an estimated volume of 300 cy of excavated soil. The locations of the AOCs are presented on Plate 7-3. The location of the excavated soil staging area is presented on Plate 7-2.

Each AOC will be demarcated with white marking paint by the RA environmental consultant. The RA contractor will use an excavator in conjunction with a front loader to remove contaminated soil from the AOCs. The front loader will transport excavated soil to the soil staging area, where stockpiles of approximately 150 cy will be created, covered with plastic and labeled.

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Excavation areas and the soil staging area will be controlled to avoid dust generation using water as a dust suppressant as discussed in Section 7.6. Additional excavation may be necessary depending on the results of confirmation sampling, as discussed in Section 7.7.2.

7.5 METEOROLOGICAL AND AIR MONITORING
This section details the meteorological and air monitoring strategy and methodologies that will be used at the Project Site during the soil RA. The strategy and methodologies are designed to achieve several goals:
• Identify and measure the air contaminants generated during the earth moving activities to assign the appropriate personal protective equipment (PPE) and safety systems specified for those activities.
• Provide feedback to site operations personnel regarding potential hazards from exposure to hazardous air contaminants generated through site activities. • Identify and measure air contaminants at points outside of the earth moving activity zones.

Air monitoring will be conducted during work activities to measure potential exposure of sensitive receptors to site chemical constituents, as a result of earth moving activities.

7.5.1 Meteorological Monitoring
Ambient weather conditions including temperature, relative humidity, wind speed, and wind direction, will be monitored onsite during earth moving activities by the RA environmental consultant using a portable weather meter and wind sock. The meteorological equipment will be checked and recorded every hour during earth moving activities.

7.5.2 Site Air Monitoring
Air monitoring will be performed during all Project Site activities in which contaminated soils are being handled or disturbed. During earth moving operations dust levels will be monitored at the following locations:
• One upwind location;
• One exclusion zone location; and
• Two downwind (fence line) locations.

Air/dust monitoring locations will change daily in accordance with excavation location and wind direction. Dust levels will be monitored using particulate meters (Thermo Scientific PDR 1500 or equivalent). The particulate meters will be operated in data logging mode and used to measure and record real-time airborne dust concentrations. The locations of the meters will be determined each day by the Site Safety Manager or designated personnel, and will be based on the daily prevailing wind direction. The particulate meters will be checked approximately every 15 to 20 minutes during the course of earth moving activities. Each time the meters are checked, the difference between the average upwind dust concentration, and the average downwind dust concentrations, will be compared to the CARB ambient air quality standard of 0.05 mg/m 3 for total
dust (24-hour average for PM10). This standard has been selected as the fence line action level and as previously described in Section 6.1.2, is protective of the public community health. Dust

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control measures will be implemented to comply with these standards, as needed. Site air monitoring action levels are presented in Table 7-1.

7.5.2.1 Site Worker Air Monitoring
As previously described in Section 6.3, dust exposure levels for each COC were calculated. Comparing the calculated dust exposure levels for each COC to their respective PEL shows that the selected air monitoring action level for the exclusion zone is pro tective of site worker health. Dust control measures as described in Section 7.7 will be implemented when total dust levels reach within 50% of the Cal-OSHA PEL for total dust. Therefore, the site action level within the exclusion zone will be 5 mg/m

3. Air monitoring action levels to be implemented during the RA activities are presented in Table 7-1.

Table 7-1: Site Air Monitoring Action Levels
Chemical of
Concern
Calculated Dust
Exposure Level(a)

CAL/OSHA PEL
Exclusion Zone
Action Level
(50% of PEL)
Fence Line
Action Level (b)
Chlordane 0.00013 mg/m3 0.5 mg/m3 --- ---
Lead 0.0031 mg/m3 0.05 mg/m3 --- ---
Total Dust --- 10 mg/m3 5 mg/m3 0.05 mg/m3
Notes:

PEL - permissible exposure limit (8-hour, time-weighted average (TWA)). (a) – Calculated using 10 mg/m3 total dust.
(b) – California ambient air quality standard (24 hour average for PM10).

7.6 DUST CONTROL PLAN
The RA contractor will implement appropriate procedures to control the generation of airborne dusts during the course of the soil removal activities. Such procedures will include, but will not be limited to the following:
• The Project Site air monitoring professional will monitor dust levels in the locations outlined in Section 7.5.2, and will have the authority to stop-work in the event that onsite activities generate dust levels in excess of the California ambient air quality standards for particulate matter (0.05 mg/m
3). Additionally, dust control measures will be taken if visible dust emissions are observed from the point-of-origin. Generation of dust during the removal operations will be minimized as necessary with the use of water as a dust suppressant. The water will be available via a water truck or a metered discharge from a fire hydrant located proximate to the Project Site. The RA contractor will control dust generation by spraying water prior to daily work activities, during excavation/loading activities (as necessary to maintain concentrations below action levels), and at truck

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staging locations. Watering equipment will be continuously available to provide proper dust control.
• T he air monitoring professional will monitor onsite meteorological instrumentation and/or coordinate with offsite meteorological professionals to identify conditions that require cessation of wor k. If wind speeds become elevated, initially, the increased application of water suppressant (water) will be employed. If an uncontrollable condition occurs (e.g. exceeding action levels for COC), all removal activities will cease, stockpiled soil(s) will be covered, and the excavation areas will be covered, if necessary. Work activities will not resume until conditions are stabilized or mitigation and/or effective engineering control measures are implemented and conditions are found acceptable to proceed.
• Padre will provide measurement of airborne dust levels at locations outlined in Section

7.5.2 using real-time, data-logging particulate monitors (Thermo Scientific PDR 1500 or equivalent). These instruments will be calibrated daily and monitoring information posted daily, and discussed with Site workers. The monitors will be visually read every 20 minutes. In consultation with DTSC, the frequency may be changed based on site conditions and newly available data. Additionally, the particulate meters will be set to log dust levels over 5 minute periods.
• During the course of all soil disturbing activities (including excavation, truck loading, soil tilling activities) dust levels will be monitored at one location upwind of the exclusion zone; one location within the exclusion zone; and two locations downwind and outside the work zone, with one located closest to the nearest residences. • Dust control measures will be increased in the event particulate concentrations exceed

0.05 mg/m
3 and/or if visible dust emissions are observed from the point-of-origin. • Perimeter fencing will be equipped with wind/dust/privacy screens for added off -site dust control.

7.7 SAMPLING AND ANALYSIS PLAN

7.7.1 Waste Profiling Sampling
Stockpiled soil will be profiled for acceptance by the selected disposal facilities. Waste characterization will include chemical analysis for OCPs and CAM 17 Metals . An acceptance letter from each selected disposal facility will be obtained before any excavated soil leaves the Project Site. Upon request, additional documentation will be provided to DTSC pertaining to waste disposal profiles and waste disposal acceptance prior to any offsite shipments of waste.

It is anticipated that soils excavated from the Project Site will be managed (handled, transported and disposed of) as: (Select all that are applicable) ☐ a hazardous waste requiring compliance with requirements of land ban restrictions. ☐ a hazardous waste requiring no compliance with requirements of land ban restrictions. ☐ a PCB waste (>50 ppm).

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☒ a non-hazardous and non-PCB waste.

7.7.2 Confirmation Sampling
Confirmation soil samples will be collected when the extent of planned excavation activities have been completed. Soil samples will be collected from the bottom and side walls of each excavation trench. In general sampling of the excavation bottom will be conducted at a frequency of one sample for every 250 square feet of excavation bottom or a minimum of one sample for every excavation bottom less than 250 square feet. Sidewall confirmation sampling will be conducted at a frequency of one sample for every 20-25 linear feet of continuous sidewall or one sample per sidewall if less than 25 linear feet. For deeper excavations, sidewall samples will be collected at depth intervals of 2-feet. Excavation floor confirmation soil samples will be collected from approximate depths of 0 to 6 inches. Additionally, the sidewall soil confirmation samples will be collected at a depth of approximately 6 inches from the top edge of the sidewalls.

If the confirmation soil samples do not meet the established cleanup goals, additional rounds of over-excavation and reconfirmation sampling may be necessary until all cleanup goals have been met. Proposed confirmation sample locations are presented on Plates 7-4.

Over-excavation may be necessary if the established cleanup goals are not met. Over - excavation at identified locations will generally consist of an additional lateral excavation of 5-feet for sidewall samples, and an additional vertical excavation of 1- feet for bottom samples. The actual lateral distances and vertical depths will be based on the reported concentrations of COC, and will be discussed in consultation with the DTSC Project Manager prior to performing any over- excavation activities. Confirmation soil samples for over -excavations will be conducted at a frequency of one sample every 150 square feet from the excavation bottom and one sample every 15 linear feet from the excavation sidewalls, as needed. The soil samples will be collected at a depth of 6 inches from the top edge of the sidewalls.

Soil Sample Collection
Soil samples will be collected in pre-cleaned 2- inch x 6- inch stainless steel sampling sleeves using hand-held sampling equipment. The sample sleeves will be sealed with plastic end cap, initialed, labeled with the time and date of collection, project number, and a unique sample identification number, and then placed on ice, in a cooler, for delivery to the analytical laboratory under chain-of-custody protocol.

Decontamination Procedures
Hand held field equipment that comes into contact with potentially contaminated soil will be decontaminated consistently so as to assure the quality of samples collected. Disposable equipment intended for one time use will not be decontaminated, but will be packaged for appropriate disposal. Decontamination will occur prior to and after each use of a piece of equipment. All sampling devices used will be decontaminated using the following procedures:
• Non-phosphate detergent and tap water wash, in a 5- gallon plastic tub, using a brush;
• Deionized/distilled water rinse, in a 5-gallon plastic tub; and • Final deionized/distilled water rinse in a 5-gallon plastic tub.

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7.8 TRANSPORTATION PLAN FOR OFF-SITE SOIL DISPOSAL
The waste material will be profiled and approval will be received before soil is transported off-site for lawful disposition. The stockpiled soil will be loaded into trucks, transported and properly disposed of at an approved landfill. Based on the analytical results gathered during the RAW, it is anticipated that the removed soil will be disposed of as non-hazardous waste.

Final determination of the disposal facility will be based on approval from the landfill. Once the disposal facility is selected, copies of waste profile reports used to secure disposal permission from the landfill will be provided to DTSC and included in the removal action completion report .

In addition, compliance with the land disposal restrictions and land ban requir ements for hazardous wastes will be documented and provided once it is determined which disposal facility will be used.

Excavated soil is transported and disposed of by weight (i.e., tonnage). Cubic-yards of soil are converted to tons by multiplying the in-situ soil volume by an expansion factor of 1.2, and a conversion factor 1.35 to obtain the soil amount in tons.

Where as:
• In-situ soil volume (cy) x 1.2 (expansion factor) x 1.35 (conversion factor) = tons • 300 cy x 1.2 (expansion factor) x 1.35 (conversion factor) = 486 tons. • 486 tons ÷ 22 tons per load = 22 truck and trailer loads.

Based on the PEA and SSI soil analytical results and proposed excavation activities, the excavated soil is anticipated to be disposed of as a non -hazardous waste. The following waste facility has been identified to accept and store and/or treat non-hazardous soil generated from the removal activities:

Non-Hazardous Waste Landfill (Class II)
Newby Island Sanitary Landfill
1601 Dixon Landing Road
Milpitas, California 95035
(408) 262-2871
In the event that waste characterization identifies that the soil is required to be disposed of as a non-RCRA hazardous waste, the following waste facilities have been identified to accept and store and/or treat non-RCRA hazardous soil generated from the removal activities:

Hazardous Waste Landfill (Class I)
Clean Harbors, LLC
Buttonwillow (Hazardous Waste Facility)
2500 West Lokern Road
McKittrick, California 93251
(661) 762-6200
Detailed information on waste transportation and disposal is described in the Transportation Plan (Appendix H).

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7.9 BACKFILL AND SITE RESTORATION
After the completion of RA activities and the removal of all building foundations, the Project Site will be re-graded and restored to meet the needs of the final school site design. Imported fill material is not anticipated. However, if needed clean imported fill material will be verified in accordance with the current DTSC Information Advisory on Clean Import ed Fill Material dated October 2001. A copy of the DTSC advisory is presented in Appendix I. Pre-construction and post-construction erosion control BMPs will be implemented as required.

7.10 VARIANCE OR EXPLANATION OF SIGNIFICANT DIFFERENCES (ESD) After the RAW is approved and finalized, new information may be received or generated that could affect the implementation of the remedy selected in this RAW (as specified in Section

5.3), or could prompt the reassessment of that remedy. Appropriate actions should be taken to address the newly developed situations (which are deviated from or are not covered by the approved RAW). New information may include:
• A change in scope, performance or cost of the selected remedy; and • Advances in remediation science and technology which may impact the remedy selection.

Within 24 hours after discovering the new information the responsible party will:
• Notify DTSC by telephone call and/or email;
• In consultation with DTSC, take an appropriate action.

7.10.1 Fundamental, Significant or Minor Changes
Based on an evaluation, and depending on the extent or scope of modification being considered, one of the following three types of change may be classified, determined and followed: minor changes, significant changes or fundamental changes.

Under CERCLA, 42 U.S.C. Section 9617(c), Section 117(c) requires that, if the removal action being undertaken at a site differs significantly from the Record of Decision (ROD) for that site, EPA shall publish an explanation of the significant differences (ESD) and the reasons such changes were made. An ESD, rather than ROD amendment, is appropriate where the adjustments being made to the ROD are significant but not fundamentally alter the remedy with respect to scope, performance, or cost. For this project the Removal Action Workplan is the ROD.

7.10.2 ESD Process
The consultant will coordinate activities with DTSC when an ESD is necessary. DTSC will determine the appropriate CEQA approach for changes to the Project.

Project Supervisor:

JEROME K. SUMMERLIN, C.E.G., C.Hg.
(805) 218-0109
Site Safety Officer:

ALAN CHURCHILL, P.G.
(916) 952-5421
Removal Contractor:

Removal Contractor:

REMOVAL ACTION
Cupertino Unified School District
Sedgwick Elementary Expansion Project
Cupertino, California
SITE

VISITORS
Project Manager:

ALAN J. KLEIN, R.E.P.A., C.E.P.S.C.
(916) 947-4831
Field Personnel:

PADRE ASSOCIATES, INC.

Site Safety Officer:

REMOVAL

CONTRACTOR PADRE STAFF
FIELD

PERSONNEL
Removal Contractor:

SUB-

CONTRACTORS

PROJECT

MANAGER
PADRE ASSOCIATES, INC. PADRE ASSOCIATES, INC.
associates, inc.

ENGINEERS, GEOLOGISTS &

ENVIRONMENTAL SCIENTISTS
AJK
DR. BY
AC
APP. BYORGANIZATION CHART
DATE
PROJECT NO.

PLATE 7-1
7/13/17 1601-3361

WORKSHOP

SINGLE-ROOM

DWELLING

OVERHANG

OVERHANG

RESIDENCE

PHIL LANE

SOIL STOCKPILE

AREA TRUCK LOADING
AREA

INGRESS
EGRESS

TRUCK INSPECTION
AREA
DECON
(WORKERS)
DECON
(EQUIPMENT)

SUPPORT ZONEPROJECT SITE BOUNDARY

EXCLUSION ZONE BOUNDARY

ESTIMATED EXTENT OF
COCs

TRUCK ROUTE
associates, inc.

ENGINEERS, GEOLOGISTS &

ENVIRONMENTAL SCIENTISTS
PLATE 7-2
DR. BY
AC
APP. BYWORK ZONES
DATE
PROJECT NO.
7/26/17AJK 1601-3361

RESIDENCE

PROJECT SITE BOUNDARY
AOC - A (approx. 240 yd³)
AOC - B (approx. 50 yd³)
AOC - C (approx. 10 yd³)
associates, inc.

ENGINEERS, GEOLOGISTS &

ENVIRONMENTAL SCIENTISTS
PLATE 7-3
DR. BY
AC
APP. BYEXCAVATION PLAN
DATE
PROJECT NO.
7/28/17AJK 1601-3361

RESIDENCE

PROJECT SITE BOUNDARY
EXCAVATION AREA (approx. 300 yd³)
CONFIRMATION SOIL SAMPLE (OCPs)

CONFIRMATION SOIL SAMPLE (LEAD)
CONFIRMATION SOIL SAMPLE (OCPs, LEAD)
associates, inc.

ENGINEERS, GEOLOGISTS &

ENVIRONMENTAL SCIENTISTS
PLATE 7-4
DR. BY
AC
APP. BYCONFIRMATION SOIL SAMPLES
DATE
PROJECT NO.
7/31/17AJK 1601-3361

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8.0 PROJECT SCHEDULE AND REPORT OF COMPLETION
The District is prepared to proceed with removal activities within one year of DTSC issuing approval of the Draft RAW. Table 8-1 summarizes the anticipated schedule of implementation and subsequent reporting for this project. A Removal Action Completion Report (RACR), documenting all activities conducted pursuant to an approved RAW and certifying that all activities have been conducted consistent with this RAW, will be prepared as expeditiously as possible upon completion of the RA and submitted to DTSC for review and approval.

Table 8-1: Schedule of Tasks
Task Days to
Complete
Cumulative
Days
Notes

1. RA Site
Preparation 10-15 10-15
Contractor coordination; Field
Work Notice; Site Control; and
Equipment Staging.

2. Soil Excavation
and Soil Staging 10-15 20-30 Assumes no weather delays.

3. Confirmation
Soil Sampling
and Waste
Characterization
5-10 25-40
Site restoration activities can
begin upon consent of
confirmation samples.

4. Landfill Approval 10 35-50
Assumes RA Contractor has
provided facility with pre-
notification.

5. Soil Loading,
Transportation
and Disposal
5-10 40-60
Assumes Contractor has pre-
scheduled with trucking
company.

6. RACR 30 70-90

7. DTSC Site
Certification 45 115-135

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9.0 REFERENCES
Bay Area Air Quality Management District.

CalEPA, DTSC, Interim Guidance, Evaluation of School Sites with Potential Contamination as a Result of Lead from Lead-Based-Paint, Organochlorine Pesticides from Temiticides, and Polychlorinated Biphenyls from Electrical Transformers, revised June 9, 2006.

CALEPA, DTSC, Envirostor Database.

CalEPA, DTSC – Human and Ecological Risk Office (HERO), Human Health Risk Assessment Note Number: 3, DTSC -modified Screening Levels (DTSC -SLs), June 2017 – Interim Update.

California, Department of Water Resources (http://www.water.ca.gov/waterdatalibrary/) California, Geological Survey, A General Location Guide For Ultramafic Rocks in California - Areas More Likely to Contain Naturally Occurring Asbestos . Open File Repor t 2000-19, 2000.

California Division of Mines and Geology, Geologic Map of San Francisco – San Jose Quadrangle California, (1:250,000), 1990 (Second Printing 2005).

California, State Water Resources Control Board Geotracker website (http://geotracker.swrcb.ca.gov).

City of Cupertino Planning Department, Cupertino General Plan Community Vision 2015 – 2040, October 2015
City of Cupertino Planning Department, Zoning Map, April 2017 Cornerstone Earth Group, Phase I Environmental Site Assessment and Preliminary Soil Quality Evaluation, 10480 Finch Avenue, Cupertino, California, July 11, 2014.

County of Santa Clara - Assessor’s Office
County of Santa Clara – Planning Department
Jennings, C.W., Fault Activity Map of California and Adjacent Areas, California Division of Mines and Geology, 1994.

Jennings and Bryant, Fault Activity Map of California, California Geological Survey, 2010.

LSA, Apple Campus 2 Project – Environmental Impact Report, State Clearinghouse No. 2011082055, June 2013.

Norris, R. M., & R. W. Webb, 1976 (Second Edition 1990), Geology of California, John Wiley & Sons, New York, pp. 412-427.

Padre Associates, Inc., Geologic Hazards Report, Sedgwick Elementary School Expansion Project, 10480 Finch Avenue, Cupertino, Santa Clara County, California, January 2015.

Preliminary Environmental Assessment, Sedgwick Elementary School Expansion Project, 10480 Finch Avenue, Cupertino, Santa Clara County, California, September 2015.

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Preliminary Environmental Assessment Workplan, Sedgwick Elementary School Expansion Project, 10480 Finch Avenue, Cupertino, Santa Clara County, California, May 2015.

Technical Memorandum, Sedgwick Elementary School Expansion Project, 10480 Finch Avenue, Cupertino, Santa Clara County, California Cupertino Union School District, September 2015.

Supplemental Site Investigation Summary Report, Sedgwick Elementary School Expansion Project, 10480 Finch Avenue, Cupertino, Santa Clara County, California Cupertino Union School District, January 2016.

Santa Clara Valley Habitat Agency (http://scv-habitatagency.org/178/Santa-Clara-Valley-Habitat- Plan)
United States Department of Agriculture, National Resources Conservation Service, Web Soil Survey (http://websoilsurvey.nrcs.usda.gov/app/).

USGS Geological Survey; Cupertino Quadrangle, California, Topographic Map, 1991.

APPENDIX A

DTSC’S FINAL PEA AND SSI APPROVAL LETTER

APPENDIX B

ASSESSOR’S PARCEL MAP

APPENDIX C

CONCEPTUAL SITE MODEL

AND PEA / SSI DATA SHEETS

Cupertino USD - PEA
Project No. 1401-2172

4-8
Table 4-1 - Soil Results for OCPs
(results in µg/kg)

Sample
Identification
Aldrin
(a,b,d)-BHC
Gamma-BHC
Chlordane-
technical
DDD
DDE
DDT
Dieldrin
Endosulfan I
Endosulfan II
Endosulfan
Sulfate
Endrin
Endrin
Aldehyde
Endrin Ketone
Heptachlor
Heptachlor
Epoxide
Methoxychlor
Hexachloro
benzene
Hexachloro
cyclopentadiene
Toxaphene
PEA (July 2015)
P-1 (SURF) <10 <10 <10 3,700 <10 350 260 <10 <10 <10 <10 <10 <10 <10 <10 23 <10 <100 <200 <500 P-1 (SURF)DUPE <20 <20 <20 2,800 <20 290 210 <20 <20 <20 <20 <20 <20 <20 <20 31 <20 <200 <400 <1,000 P-1 (1-1.5’) <1.0 <1.0 <1.0 87 <1.0 9.5 5.9 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 0.86J <1.0 <10 <20 <50 P-2 (SURF) <1.0 <1.0 <1.0 120 <1.0 77 44 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 4.8 <1.0 <10 <20 <50 P-2 (1-1.5’) <1.0 <1.0 <1.0 <25 <1.0 0.46J <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <10 <20 <50 P-3 (SURF) <10 <10 <10 1,200 <10 56 46 <10 <10 <10 <10 <10 <10 <10 <10 4.0J <10 <100 <200 <500 P-3 (1-1.5’) <1.0 <1.0 <1.0 220 <1.0 6.5 8.2 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <10 <20 <50 P-4 (SURF) <1.0 <1.0 <1.0 2,900 <1.0 140 130 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 7.4 <1.0 <10 <20 <50 P-4 (1-1.5’) <10 <10 <10 1,100 <10 44 38 <10 <10 <10 <10 <10 <10 <10 <10 7.8J <10 <100 <200 <500 P-5 (SURF) <1.0 <1.0 <1.0 63 0.76 J 24 24 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 1.6 <1.0 <10 <20 <50 P-5 (1-1.5’) <1.0 <1.0 <1.0 <25 <1.0 0.93J 1.1 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <10 <20 <50 P-6 (SURF) <10 <10 <10 3,400 <10 120 210 <10 <10 <10 <10 <10 <10 <10 <10 6.0J <10 <100 <200 <500 P-6 (1-1.5’) <1.0 <1.0 <1.0 <25 <1.0 0.94J 0.73J <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <10 <20 <50 P-7 (SURF) <10 <10 <10 1,900 <10 120 110 <10 <10 <10 <10 <10 <10 <10 <10 26 <10 <100 <200 <500 P-7 (1-1.5’) <1.0 <1.0 <1.0 <25 <1.0 1.4 1.1 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <10 <20 <50 P-8 (SURF) <1.0 <1.0 <1.0 57 <1.0 14 11 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 3.3 <1.0 <10 <20 <50 P-8 (1-1.5’) <1.0 <1.0 <1.0 <25 1.1 3.9 3.4 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <10 <20 <50 P-9 (SURF) <1.0 <1.0 <1.0 2,100 <1.0 53 120 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 13 <1.0 <10 <20 <50 P-9 (SURF) DUPE <10 <10 <10 1,800 <10 47 120 <10 <10 <10 <10 <10 <10 <10 <10 8.3J <10 <100 <200 <500 P-9 (1-1.5’) <1.0 <1.0 <1.0 38 0.35J 3.9 12 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <10 <20 <50 P-10 (SURF) <1.0 <1.0 <1.0 13,000 <1.0 39 160 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 21 57 <1.0 <10 <20 <50 P-10 (1-1.5’) <1.0 <1.0 <1.0 40 <1.0 1.4 4.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <10 <20 <50 P-10 (1-1.5’) DUPE <1.0 <1.0 <1.0 38 <1.0 1.9 4.8 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 1.0 <1.0 <10 <20 <50 P-11 (SURF) <1.0 <1.0 <1.0 930 <1.0 35 93 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 4.0 <1.0 <10 <20 <50 P-11 (1-1.5’) <1.0 <1.0 <1.0 95 <1.0 12 24 0.53J <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 1.8 <1.0 <10 <20 <50 P-12 (SURF) <1.0 <1.0 <1.0 110 <1.0 12 18 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 1.2 <1.0 <10 <20 <50 P-12 (1-1.5’) <1.0 <1.0 <1.0 <25 0.41J 2.7 6.3 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <10 <20 <50 P-14 (SURF) <1.0 <1.0 <1.0 60 2.2 97 61 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 0.25J 0.71J <1.0 <10 <20 <50 P-14 (1-1.5’) <1.0 <1.0 <1.0 <25 0.47J 14 9.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <10 <20 <50 P-15 (SURF) <1.0 <1.0 0.49J 1,500 <1.0 410 160 6.8 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 11 <1.0 <10 <20 <50 P-15 (1-1.5’) <1.0 <1.0 <1.0 <25 9.3 50 36 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 1.4 <1.0 <10 <20 <50 HHRA NOTE #3 430
RSLs 39 -- 570 1,700 2,300 2,000 1,900 34 -- -- -- -- -- -- 130 70 -- 210 -- 490

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Table 4-1 - Soil Results for OCPs (cont’)
(results in µg/kg)
Sample
Identification
Aldrin
(a,b,d)-BHC
Gamma-BHC
Chlordane-
technical
DDD
DDE
DDT
Dieldrin
Endosulfan I
Endosulfan II
Endosulfan
Sulfate
Endrin
Endrin
Aldehyde
Endrin Ketone
Heptachlor
Heptachlor
Epoxide
Methoxychlor
Hexachloro
benzene
Hexachloro
cyclopentadiene
Toxaphene
P-15 (1-1.5’) DUPE <1.0 <1.0 <1.0 <25 8.9 50 31 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 1.5 <1.0 <10 <20 <50 P-16 (SURF) <1.0 <1.0 <1.0 170 3.3 4.5 18 2.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 1.3 <1.0 <10 <20 <50 P-25 (SURF) <1.0 <1.0 <1.0 <25 0.49J 62 25 0.43J <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <10 <20 <50 P-25 (1-1.5’) <1.0 <1.0 <1.0 <25 <1.0 2.6 2.7 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <10 <20 <50 P-26 (SURF) <1.0 <1.0 <1.0 <25 <1.0 43 23 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <10 <20 <50 P-26 (1-1.5’) <1.0 <1.0 <1.0 <25 <1.0 3.1 1.8 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <10 <20 <50 P-27 (SURF) <1.0 <1.0 <1.0 <25 2.8 150 62 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <10 <20 <50 P-27 (1-1.5’) <1.0 <1.0 <1.0 <25 <1.0 1.3 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <10 <20 <50 SSI (October 2015)
SS-6A (SURF) <1.0 <1.0 <1.0 <25 0.54J 12 6.5 0.42J <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 0.65J <1.0 <1.0 <10 <20 <50 SS-6A (1-1.5’) <1.0 <1.0 <1.0 <25 0.53J 6.9 4.6 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <10 <20 <50 SS-6B (SURF) <2.0 <2.0 <2.0 <50 1.2J 25 15 1.5 J <2.0 <2.0 <2.0 <2.0 <2.0 <2.0 <2.0 <2.0 <2.0 <20 <40 410 SS-6B (1-1.5’) <1.0 <1.0 <1.0 <25 <1.0 0.98J 1.4 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <10 <20 <50 SS-6C (SURF) <1.0 <1.0 <1.0 <25 1.2 17 16 0.85J <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 0.35J <1.0 <10 <20 <50 SS-6C (1-1.5’) <1.0 <1.0 <1.0 <25 <1.0 5.0 2.1 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <10 <20 <50 SS-6D (SURF) <1.0 <1.0 <1.0 37 0.87J 11 14 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 0.39J <1.0 <10 <20 <50 SS-6D (1-1.5’) <1.0 <1.0 <1.0 <25 <1.0 4.2 1.3 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <10 <20 <50 SS-6E (SURF) <1.0 <1.0 <1.0 44 2.5 21 20 0.54J <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 1.0 <1.0 <10 <20 <50 SS-6E (1-1.5’) <1.0 <1.0 <1.0 <25 <1.0 0.45J <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 0.26 J <1.0 <1.0 <10 <20 <50 P-4A (2-2.5’) <1.0 <1.0 <1.0 20J <1.0 0.99J 1.2 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <10 <20 <50 P-10A (SURF) <1.0 <1.0 <1.0 130 1.6 6.5 7.3 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <10 <20 <50 P-10A (1-1.5’) <1.0 <1.0 <1.0 <25 <1.0 2.2 7.8 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 0.29 J <1.0 <1.0 <10 <20 <50 P-10B (SURF) <1.0 <1.0 <1.0 500 1.6 7.8 8.5 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 0.94 J 5.2 <1.0 <10 <20 <50 P-10B (1-1.5’) <1.0 <1.0 <1.0 <25 <1.0 1.0 1.7 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 0.23J <1.0 <10 <20 <50 P-10C (SURF) <1.0 <1.0 <1.0 1,700 <1.0 5.3 5.8 <1.0 <1.0 <1.0 <1.0 2.1 <1.0 <1.0 0.76 J 19 <1.0 <10 <20 <50 P-10C (1-1.5’) <1.0 <1.0 <1.0 410 2.8 6.1 4.3 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 4.8 <1.0 <10 <20 <50 P-10D (SURF) <1.0 <1.0 <1.0 4,800 <1.0 28 81 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 5.4 30 <1.0 <10 <20 <50 P-10D (1-1.5’) <1.0 <1.0 <1.0 31 0.33J 2.7 7.4 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 0.28J <1.0 <10 <20 <50 P-11A (SURF) <1.0 <1.0 <1.0 100 1.8 12 27 0.76J <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 1.2J <1.0 <10 <20 <50 P-11A (1-1.5’) <1.0 <1.0 <1.0 83 2.1 6.9 14 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <10 <20 <50 HHRA NOTE #3 430
RSLs 39 -- 570 1,700 2,300 2,000 1,900 34 -- -- -- -- -- -- 130 70 -- 210 -- 490

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Table 4-1 - Soil Results for OCPs (cont’)
(results in µg/kg)
Sample
Identification
Aldrin
(a,b,d)-BHC
Gamma-BHC
Chlordane-
technical
DDD
DDE
DDT
Dieldrin
Endosulfan I
Endosulfan II
Endosulfan
Sulfate
Endrin
Endrin
Aldehyde
Endrin Ketone
Heptachlor
Heptachlor
Epoxide
Methoxychlor
Hexachloro
benzene
Hexachloro
cyclopentadiene
Toxaphene
P-11B (SURF) <1.0 <1.0 <1.0 650 4.3 26 55 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 4.7 <1.0 <10 <20 <50 P-11B (SURF) DUPE <1.0 <1.0 <1.0 470 4.4 21 44 1.7 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 0.71J 3.8 <1.0 <10 <20 <50 P-11B (1-1.5’) <1.0 <1.0 <1.0 58 <1.0 3.8 9.8 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 0.32J 0.55 J <1.0 <10 <20 <50 P-15A (SURF) <1.0 <1.0 <1.0 190 6.4 150 55 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 2.4 <1.0 <10 <20 <50 P-15A (1-1.5’) <1.0 <1.0 <1.0 <25 1.7 9.2 7.1 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 0.34J <1.0 <1.0 <10 <20 <50 P-15A (1-1.5’) DUPE <1.0 <1.0 <1.0 <25 0.99J 6.2 6.5 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <10 <20 <50 Phase II (July 2014)
SS-1* <9.9 <9.9 <9.9 <200 21 320 87 <9.9 <9.9 9.9 <9.9 <9.9 <9.9 <9.9 <9.9 <9.9 <9.9 -- -- <200 SS-2* <2.0 <2.0 <2.0 <40 26 280 33 <2.0 <2.0 <2.0 <2.0 <2.0 <2.0 <2.0 <2.0 <2.0 <2.0 -- -- <40 SS-3* <2.0 <2.0 <2.0 <39 26 280 33 <2.0 <2.0 <2.0 <2.0 <2.0 <2.0 <2.0 <2.0 <2.0 <2.0 -- -- <39 SS-4* <2.0 <2.0 <2.0 180 31 230 26 <2.0 <2.0 <2.0 <2.0 <2.0 <2.0 <2.0 <2.0 <2.0 <2.0 -- -- <39 SS-5* <20 400 280 2,800 26 360 91 <20 <20 <20 <20 <20 <20 <20 <20 <20 <20 -- -- <400 SS-6* <2.0 86 50 520 28 55 26 8.7 <2.0 <2.0 <2.0 <2.0 <2.0 <2.0 <2.0 12 <2.0 -- -- <40 SS-7* <2.0 5.9 3.7 <40 29 240 26 2.9 <2.0 <2.0 <2.0 <2.0 <2.0 <2.0 <2.0 <2.0 <2.0 -- -- <40 SS-8* <2.0 <2.0 <2.0 <40 21 120 14 <2.0 <2.0 <2.0 <2.0 <2.0 <2.0 <2.0 <2.0 <2.0 <2.0 -- -- <40 SS-9* <2.0 7.0 5.5 67 48 260 29 <2.0 <2.0 <2.0 <2.0 <2.0 <2.0 <2.0 <2.0 <2.0 <2.0 -- -- <40 SS-10* <2.0 <2.0 <2.0 <40 31 220 16 <2.0 <2.0 <2.0 <2.0 <2.0 <2.0 <2.0 <2.0 <2.0 <2.0 -- -- <40 SS-11* <2.0 3.2 3.5 <39 32 180 21 <2.0 <2.0 <2.0 <2.0 <2.0 <2.0 <2.0 <2.0 <2.0 <2.0 -- -- <39 SS-12* <9.7 25 31 240 17 150 60 <9.7 <9.7 <9.7 <9.7 <9.7 <9.7 <9.7 <9.7 <9.7 <9.7 -- -- <190 SS-13* <2.0 15 12 110 21 42 14 <2.0 <2.0 <2.0 <2.0 <2.0 <2.0 <2.0 <2.0 <2.0 <2.0 -- -- <40 SS-14* <9.8 <9.8 <9.8 <200 28 410 88 <9.8 <9.8 <9.8 <9.8 <9.8 <9.8 <9.8 <9.8 <9.8 <9.8 -- -- <200 SS-15* <2.0 3.5 3.9 <40 47 190 26 <2.0 <2.0 <2.0 <2.0 <2.0 <2.0 <2.0 <2.0 <2.0 <2.0 -- -- <40 SS-16* <1.9 <1.9 <1.9 <39 <1.9 8.8 <1.9 <1.9 <1.9 <1.9 <1.9 <1.9 <1.9 <1.9 <1.9 <1.9 <1.9 -- -- <39 HHRA NOTE #3 430
RSLs 39 -- 570 1,700 2,300 2,000 1,900 34 -- -- -- -- -- -- 130 70 -- 210 -- 490 Notes:
µ g / k g – m i c r o g r a m s p e r k i l o g r a m * Surface soil sample (Cornerstone, June 2014)
-- Not reported
HHRA – Human Health Risk Assessment Note #3, Table 1 (May 2015).

R S L – U . S . EPA Regional Screening Levels (June, 2015) 3 , 700 – above screening level

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Table 4-2 - Soil Results for Arsenic and Lead
(results in mg/kg)
Sample
Identification Arsenic Lead
U.S. EPA Method 6020 6020
PEA (July 2015)
SS-6A (1-1.5’) 11 --
AS-1 (SURF) 13 --
AS-2 (SURF) 7.2 --
AS-3 (SURF) 5.7 --
P-7 (SURF) -- 39
P-7 (1-1.5’) -- 79
P-10 (SURF) -- 29
P-10 (1-1.5’) -- 9.3
P-11 (SURF) -- 24
P-11 (1-1.5’) -- 13
P-13 (SURF) -- 92
P-13 (1-1.5’) -- 17
P-14 (SURF) -- 36
P-15 (SURF) -- 220
P-17 (SURF) -- 310
P-17 (SURF) DUP -- 310
P-17 (1-1.5’) -- 43
P-18 (SURF) -- 93
P-18 (1-1.5’) -- 17
P-19 (SURF) -- 180
P-19 (1-1.5’) -- 31
P-19 (1-1.5’) DUPE -- 27
P-20 (SURF) -- 35
P-20 (1-1.5’) -- 11
P-21 (SURF) -- 40
P-21 (1-1.5’) -- 9.4
P-23 (SURF) -- 42
P-23 (1-1.5’) -- 13
Screening Level AB 80B

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Table 4-2 - Soil Results for Arsenic and Lead (cont’)
(results in mg/kg)

Sample
Identification Arsenic Lead
U.S. EPA Method 6020 6020
P-24 (SURF) -- 83
P-24 (1-1.5’) -- 10
P-24 (1-1.5’) DUP -- 9.0
P-25 (SURF) -- 47
P-25 (1-1.5’) -- 9.8
P-26 (SURF) -- 29
P-26 (1-1.5’) -- 12
P-27 (SURF) -- 64
P-27 (SURF) DUP -- 39
P-27 (1-1.5’) -- 14
P-28 (SURF) -- 150
P-28 (1-1.5’) -- 12
SSI (October 2015)
P-13A (SURF) -- 68
P-13B (SURF) -- 62
P-15A (SURF) -- 31
P-17A (SURF) -- 73
P-17A (SURF) DUPE -- 60
P-28A (SURF) -- 65
P-29 (SURF) -- 39
P-29A (SURF) -- 36
P-30 (SURF) -- 65
P-31 (SURF) -- 41
P-32 (SURF) -- 42
P-33 (SURF) -- 49
Screening Level AB 80B

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Table 4-2 - Soil Results for Arsenic and Lead (cont’)
(results in mg/kg)

Sample
Identification Arsenic Lead
U.S. EPA Method 6020 6020
Phase II (June 2014)
SS-1 11 40
SS-2 12 100
SS-3 8.7 20
SS-4 7.3 23
SS-5 13 51
SS-6 15 75
SS-7 8.0 20
SS-8 7.8 18
SS-9 7.8 42
SS-10 8.9 27
SS-11 6.4 19
SS-12 8.2 72
SS-13 5.2 52
SS-14 8.9 33
SS-15 6.6 22
SS-16 6.8 9.0
Screening Level AB 80B

Notes:

mg/kg milligrams per kilogram
‘--‘ Not analyzed

150 Above screening level
AB Ambient background concentration
B OEHHA Leadspread Version 8

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Table 6-3 - Soil Results for PCBs
(results in mg/kg)
Sample
Identification
Aroclor
1016
Aroclor
1221
Aroclor
1232
Aroclor
1242
Aroclor
1248
Aroclor
1254
Aroclor
1260
PCBs
Total
P-4 (SURF) <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 P-9 (SURF) <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 P-10 (SURF) <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 P-11 (SURF) <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 P-14 (SURF) <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 P-15 (SURF) <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 RSLs 0.23 0.17 0.17 0.23 0.23 0.12 0.24 0.24

Notes:
mg/kg – milligrams per kilogram
RSLs– U.S. EPA Regional Screening Level (June 2015)

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Table 6-4 – Soil Results for TPHg, BTEX, and MTBE
(results in mg/kg)
Sample
Identification
TPH-
Gasoline
(C6 –C12)
Benzene Toluene Ethyl-
Benzene
Total
Xylenes MTBE
U.S. EPA
Method 8260 8260 8260 8260 8260 8260
DH-1 (12’) 0.18 <0.0034 <0.0034 <0.0034 0.026 <0.0034
DH-1 (15’) <0.081 <0.0033 <0.0033 <0.0033 <0.0033 <0.0033 DH-1 (20’) <0.081 <0.0032 <0.0032 <0.0032 <0.0032 <0.0032 DH-2 (15’) <0.084 <0.0034 <0.0034 <0.0034 <0.0034 <0.0034 DH-2 (20’) <0.081 <0.0033 <0.0033 <0.0033 <0.0033 <0.0033 DH-3 (15’) <0.087 <0.0035 <0.0035 <0.0035 <0.0035 <0.0035 DH-3 (20’) <0.092 <0.0037 <0.0037 <0.0037 <0.0037 <0.0037 DH-4 (15’) <0.088 <0.0035 <0.0035 <0.0035 <0.0035 <0.0035 DH-4 (20’) <0.082 <0.0033 <0.0033 <0.0033 <0.0033 <0.0033 DH-5 (15’) <0.13 <0.0050 <0.0050 <0.0050 <0.0050 <0.0050 DH-5 (20’) <0.14 <0.0057 <0.0057 <0.0057 <0.0057 <0.0057 HHRA Note #3 0.33 1,100
RSL 1.2 4,900 5.8 650 47

Notes:

TPH – Total Petroleum Hydrocarbons
BTEX – Benzene, toluene, ethylbenzene, total xylenes
MTBE – Methyl tert butyl ether
HHRA – Human Health Risk Assessment Note #3, Table 1
RSL – U.S. EPA Regional Screening Level (June 2015)

Cupertino USD - PEA
Project No. 1401-2171

6-13
Table 6-5 - Soil Gas Results for TPHg and VOCs
by EPA Method TO-15 (µg/m3 of Vapor)
Sample
ID
TPH-Gasoline
Benzene
Toluene
Ethylbenzene
Total Xylenes
Methyl-t butyl ether
(MTBE)
2-Hexanone
All Other VOCs
SV-1 (5’) <720 <1.6 5.6 2.9 <6.6 <1.8 <2.1 <1.3
SV-1 (8’) <720 2.8 11 3.4 12 <1.8 5.6 <1.3
HHRA Note #3 97 310,000 1,100 100,000 11,000 31,000
RSLs 31,000 360 5,200,000 1,100 100,000 11,000 31,000

Notes:
µg/m3 – micrograms per cubic meter
TPHg – Total Petroleum Hydrocarbons as Gasoline
HHRA – Human Health Risk Assessment Note #3, Table 3. Screening level includes attenuation factor (0.001) for future residential structures.
“—“ - not established or not used
RSL – USEPA Regional Screening Level (June 2015). Screening le vel includes attenuation factor (0.001) for future residential structures.

APPENDIX D

NOTICE OF EXCEMPTION

APPENDIX D

NOTICE OF EXCEMPTION

State of California – California Environmental Protection Agency Department of Toxic Substances Control

DTSC 1332 (03/04/08)

CALIFORNIA ENVIRONMENTAL QUALITY ACT

NOTICE OF EXEMPTION

To: Office of Planning and Research
State Clearinghouse
P.O. Box 3044, 1400 Tenth Street, Room 212
Sacramento, CA 95812-3044
From: Department of Toxic Substances Control
Northern California Schools
Brownfields and Environmental Restoration Program
8800 Cal Center Drive
Sacramento, California 95826

Project Title: Sedgwick Elementary School Expansion Project Removal Action Workplan

Project Location: 10480 Finch Avenue, Cupertino, California

County: Santa Clara

Project Description: The California Department of Toxic Substances Control (DTSC), following the 30-day public review and comment period, is considering approval the Sedgwick Elementary School Expansion Project Removal Action Workplan (RAW - Padre Associates, Inc., dated January 2018) pursuant to authority granted under Chapter 6.8, Division 20, sections 25323.1 and 25356.1 of the Health and Safety Code (H&SC). The RAW was prepared on behalf of the Cupertino Union School District (District). The 1.48-acre expansion parcel is identified by the Santa Clara County Assessors Offie as Assessor’s Parcel Number 375‐40-067, and located at 10480 Finch Avenue, Cupertino, California (Site).

The project will excavate approximately 300 cubic yards of shallow soil (0 to 2 feet below ground surface), where lead and the organochlorine pesticide (OCP) chlordane were found to exceed the respective action level. The removal of the contaimanted soil reduces the human health-based risk to an acceptable standard for residential use. In 2017 the District acquired the Site for potential future expansion of the existing Sedgwick Elementary School. The District has not identified specific plans for the Site, however, the expansion will not result in the addition of classrooms or students to the existing elementary school
.

Background: The approximately 1.48 acre Site had been operated as an orchard from 1939 to 1956, and used as residential property since 1956. Two small, single-room dwellings are located to the south of a workshop. The dwellings are of wood-frame construction, resting on concrete blocks. The Site is bound to the north by Phil Lane and single family residential subdivisions; to the south by Sedgwick Elementary School playfield and single family residential subdivisions; to the west by single family residential subdivisions; and, to the east by Sedgwick Elementary School, and South Tantau Avenue and single family residential subdivisions. A 500-gallon gasoline underground storage tank (UST) was removed from the Site in 1996. Laboratory analyses of two soil samples, collected during the UST removal from below the tank, detected total petroleum hydrocarbons as gasoline, benzene, toluene, ethylbenzene, and xylenes. The Santa Clara Valley Water District subsequently issued a March 26, 1997 case closure letter stating that no further action related to the UST release was required based on removal of the UST and confirmation analytical data results.

A Preliminary Environmental Assessment (PEA) dated September 2015 and a Supplemental Site Investigation, (SSI) dated January 2016 were completed for the Site. The investigations established whether a release or potential release of hazardous materials substances, which pose a threat to human health via ingestion, dermal contact, and inhalation exposure pathways existed at the Site.

The PEA investigated for the presence of the following recognized environmental conditions that may have posed a threat to human health and the environment:

• OCPs and arsenic in soil from historic agricultural use; • L ead in soil from weathering of lead-based paint used on existing and any prevous structures; and termiticides in soil from existing and historic on-site building structures with wood components; • P polychlorinated biphenyls in soil from the weathering of sealant compounds used in existing and historic building structures; and,
• V olatile organic compounds and gasoline in soil from the former on-site UST.

The PEA Report concluded six soil samples located near the primary residence and the workshop with concentrations of COCs exceeding residential screening levels and further action was recommended to address the contaimination of pesticide and lead.

State of California – California Environmental Protection Agency Department of Toxic Substances Control

DTSC 1332 (03/04/08)
The SSI consisted of step-out and step-down soil samples to further delineate the extent of OCPs and lead contamination in the area of the main residence and to further evaluate elevated lead concentrations identified at the southeast portion of the Site. The results of the SSI were used to determine the extent of the response action at the Site.

Project Activities: . The project activities include:
• Demolition of existing structures are scheduled to be completed immediately prior to implementation of the RAW.

Demolition activities will be completed under the oversight of the environmental consultant in an effort to minimize disturbance of impacted soils.
• Excavation of approximately 300 cubic yards (approximately 20 to 25 truckloads) of soil with chlordane (pesticide) greater than 0.43 mg/kg and lead greater than 80 milligram per kilogram (mg/kg). Perform statistical analysis to verify that the estimated mean soil lead value (95% Upper Confidence Limit) of soil remaining is less than or equal to 80 mg/kg.
• S egregate and stockpile Class I and Class II contaminated soil waste to minimize waste to be disposed in a Class I landfill.
• Perform sampling and analysis of the excavated soil to facilitate waste characterization for landfill disposal. • Transport the contaminated soil off-site to a licensed disposal facility in accordance with applicable regulations. • Conduct confirmation soil sampling to verify that remedial goals have been achieved. • Import of clean soil is not proposed for this response action.

This is a small and short-term excavation project. It is anticipated that the off-haul of impacted soil will requireapproximately three weeks. Engineering controls to be implemented during excavation activities include fugitive dust prevention, track-out prevention, surface and stockpile protection, ingress/egress development, vehicl e movement, and implementation of best management practices. Noise-generating activities consisting of excavation equipment and trucks will be limited to between 8:00 a.m. to 5:00 p.m., Monday to Friday, there shall be no start-up of machines or equipment before 7:30 a.m., and no cleaning or servicing of machines or equipment past 6:00 p.m., and no weekend work will be conducted. Traffic will be coordinated with the trucking company to minimize truck traffic on surrounding surface streets and reduce dust generation during on-site transportation.

Specific environmental safeguards and monitoring procedures that are enforceable and made a condition of RAW approval are included in an approved Health and Safety Plan, Dust Control Plan, Confirmation Sampling and Analysis Plan, and Transportation Plan and Quality Assurance Project Plan.

In the event biological, cultural or historical resources are discovered in the course of project activities, work will be suspended while a qualified biologist, cultural or historical specialist makes an assessment of the area and arrangements are made to protect or preserve any resources that are discovered. If human remains are discovered, no further disturbance will occur in the location where the remains are found, and the County Coroner will be notified pursuant to Health and Safety Code Chapter 2, Section 7050.5.

Name of Public Agency Approving Project: Department of Toxic Substances Control

Name of Person or Agency Carrying Out Project: Cupertino Union School District

Exemption Status: (check one)

Ministerial [PRC, Sec. 21080(b)(1); CCR, Sec. 15268]
Declared Emergency [PRC, Sec. 21080(b)(3); CCR, Sec.15269(a)] Emergency Project [PRC, Sec. 21080(b)(4); CCR, Sec.15269(b)(c)] Categorical Exemption: Class 30 [Cal. Code Regs. title 14, §15330] Statutory Exemptions: [State code section number]
General Rule [CCR, Sec. 15061 (b) (3)]

Exemption Title: Minor Actions Taken to Prevent, Minimize, Stabilize, Mitigate, or Eliminate the Release or Threat of Release of Hazardous Waste or Hazardous Substance.

Reasons Why Project is Exempt:

1. The project is a minor action designed to prevent, minimize, stabilize, mitigate or eliminate the release or threat of release of hazardous waste or hazardous substances.

2. The project will not exceed $1 million in cost.

State of California – California Environmental Protection Agency Department of Toxic Substances Control

DTSC 1332 (03/04/08)

3. The project does not involve the onsite use of a hazardous waste incinerator or thermal treatment unit or th e 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 25123.

4. T he exceptions pursuant to Cal. Code Rags., tit. 14, § 15300.2 have been addressed as follows:
− 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. − 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. − 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.
− Hazardous Waste Sites. The project is not located on a site which is included on any list compiled pursuant to Section 65962.5 of the Government Code.
− Historical Resources. The project will not cause a substantial adverse change in the significance of a historical resource because there are none at the Site.

Evidence to support the above reasons is documented in the project file record, available for inspection at the following address:

Department of Toxic Substances Control
Brownfields and Environmental Restoration
8800 Cal Center Drive
Sacramento, California 95826

Project Manager Signature Date
Jose Luevano Hazardous Substances Engineer 916-255-3577 Project Manager Name Project Manager Title Phone No.

Branch Chief Signature Date
Mark Malinowski Supervising Engineering Geologist 916-255-3717 Branch Chief Name Branch Chief Title Phone No.

TO BE COMPLETED BY OPR ONLY
Date Received For Filing and Posting at OPR:

APPENDIX E

COMMUNITY PROFILE REPORT

APPENDIX E

COMMUNITY PROFILE REPORT

CALIFORNIA ENVIRONMENTAL PROTECTION AGENCY
Department of Toxic Substances Control
8800 Cal Center Drive
Sacramento, California 95826

COMMUNITY PROFILE

SEDGWICK ELEMENTARY SCHOOL

EXPANSION PROJECT
10480 FINCH AVENUE

CUPERTINO, SANTA CLARA COUNTY, CALIFORNIA

March 2018

COMMUNITY PROFILE SEDGWICK ELEMENTARY SCHOOL EXPANSION PROJECT i | P a g e

Table of Contents

SECTION PAGE

1.0 INTRODUCTION ....................................................................................................................... 1-1

1.1 Purpose of the Community Profile ..................................................................... 1-1

1.2 DTSC Oversight Responsibilities ....................................................................... 1-1

1.3 Sources of Information for the Community Profile ............................................. 1-1

1.4 Organization of the Community Profile .............................................................. 1-1

2.0 SITE AND COMMUNITY DESCRIPTION ............................................................................... 2-1

2.1 Site Location and Description ............................................................................ 2-1

2.1.1 Surrounding Land Uses ......................................................................... 2-1

2.1.2 Current Land Use ................................................................................... 2-1

2.2 Site History ........................................................................................................ 2-1

2.3 Community Description ...................................................................................... 2-1

2.4 Community Interest and Media Coverage ......................................................... 2-3

2.5 Community Concerns ........................................................................................ 2-4

2.6 Sensitive Receptors in the Local Area ............................................................... 2-4

3.0 PUBLIC PARTICIPATION ....................................................................................................... 3-1

3.1 Recommended Public Participation Activities .................................................... 3-1

3.2 Key Contacts ..................................................................................................... 3-2

3.3 Information Repositories .................................................................................... 3-3

3.4 DTSC Project Contacts ...................................................................................... 3-3

LIST OF TABLES
Table 1 - City of Cupertino Demographic Characteristics

APPENDICES
A Community Cover Letter and Survey Results
B Site Location Map

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1.0 INTRODUCTION

1.1 PURPOSE OF THE COMMUNITY PROFILE
This Community Profile has been prepared by the Department of Toxic Substances Control (DTSC) for the Sedgwick Elementary School expansion project located 10480 Finch Avenue in Cupertino, California 95014 (Site). This Community Profile provides the public with a description of the Site and the community in which it is located, and helps DTSC determine potential community interest in the cleanup, and recommends future public participation activities for the cleanup. In addition, the Community Profile also describes community demographics and land uses in areas surrounding the Site.

1.2 DTSC OVERSIGHT RESPONSIBILITIES
DTSC is the lead regulatory agency for making the decision for the cleanup. As the regulatory agency providing oversight, DTSC is responsible to ensure that the public and environment are protected from potential exposure to contamination. As part of the cleanup process, DTSC ensures that community members are informed about any cleanup and related activities, and that the public has an opportunity to be involved in DTSC’s decision making process.

1.3 SOURCES OF INFORMATION FOR THE COMMUNITY PROFILE
The Community Profile is prepared based on information from a variety of sources. A primary source of information for the Community Profile comes from the community itself. DTSC distributed a Community Survey to residents and businesses within a quarter-mile radius of the Site to help assess community interest and concern regarding the investigation and cleanup of the Site. A copy of the Community Survey and the survey results are included in Appendix A.

DTSC has also consulted with and reviewed information provided by the City of Cupertino to assist in preparing this Community Profile. Recent demographic information for the City of Cupertino has been researched in the preparation of the Community Profile and is provided in Section 2.3. Additionally, the Community Profile has been prepared using information from technical documents prepared for the Site.

1.4 ORGANIZATION OF THE COMMUNITY PROFILE
The Community Profile is organized in three sections; 1.0) Introduction, 2.0) Site and Community Description, and 3.0) Project Public Participation. In addition, the Key Contacts for the project have been included in Section 3.2.

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2.0 SITE AND COMMUNITY DESCRIPTION

2.1 SITE LOCATION AND DESCRIPTION
The Site is approximately 1.48-acres property near the existing Sedgwick Elementary School.

The property will expand the Sedgwick Elementary School but there are no immediate construction plans for the expansion property. Potable water and sewer services will continue to be provided by the local municipality.

2.1.1 SURROUNDING LAND USES
The Site is bound to the north by Phil Lane followed by single family residential subdivisions; to the east by Sedgwick Elementary School, followed by South Tantau Avenue and single family residential subdivisions; to the south by Sedgwick Elementary School playfield, followed by single family residential subdivisions; and, to the west by single family residential subdivisions.

2.1.2 CURRENT LAND USE
The Site is currently an existing school.

2.2 SITE HISTORY
The Site is approximately 1.48-acres and historically operated as an orchard from 1939 to 1956, and used as residential property since 1956. A 500-gallon gasoline underground storage tank was removed from the Site in 1996. A house and workshop remains on the property and will be removed immediately following the cleanup.

2.3 COMMUNITY DESCRIPTION
The City of Cupertino is in Santa Clara County and directly west of San Jose on the western edge of the Santa Clara Valley with portions extending into the foothills of the Santa Cruz Mountains. It was ranked by Forbes for having the most educated small towns, with local public schools ranking highly in the country. It is also known as the home of Apple Inc. corporate headquarters.

Cupertino in the 19th century was a small rural village at the crossroads of Stevens Creek Road and Saratoga-Mountain View Road (also known locally as Highway 9; later Saratoga- Sunnyvale Road, and then renamed to De Anza Boulevard within Cupertino city limits). Back then, it was known as the West Side and was part of Fremont Township. The primary economic activity was fruit agriculture. Almost all of the land within Cupertino's present-day boundaries was covered by prune, plum, apricot, and cherry orchards. A winery on Montebello Ridge overlooking the Cupertino valley region was also in operation by the late 19th century.

Soon railroads, electric railways, and dirt roads traversed the West Side farmlands. Monta Vista, Cupertino's first housing tract, was developed in the mid-20th century because of the electric railway's construction.

According to the 2010 U.S. Census, Cupertino has a resident population of approximately 57,965 people (99.4% of the population) lived in households, 61 (0.1%) lived in non-

COMMUNITY PROFILE SEDGWICK ELEMENTARY SCHOOL EXPANSION PROJECT 2-2 | P a g e
institutionalized group quarters, and 276 (0.5%) were institutionalized. Table 1 presents demographic information about the City of Cupertino.

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Table 1
Cupertino Demographic Characteristics
Source: 2010 U.S. Census
Category Count Percent

Total Population 58,302 100%
Race
White 18,270 31.3%
African American/Black 344 0.6%
Native Indian/American 117 0.2%
Other Race 670 1.1%
Two or More Races 1,952 3.3%
Hispanic or Latino 2,113 3.6%
Asians 36,895 63.3%
Native Hawaiian/Pacific Islander 54 0.1%

Median Household Income (2015)
76,310

Education (Population 25 years and
over (2015))
High school graduate or higher 83.4%
Bachelor’s degree or higher 23.1%

Language
Speak only English 58.4%
Speak a language other than English 41.6%

Speak English less than ‘very well’ 42.5%
5 to 17 years old 17.3%
18 to 64 years old 48.0%
65 years old and over 76.0%

2.4 COMMUNITY INTEREST AND MEDIA COVERAGE
DTSC searched of web-based sources that serve the Cupertino area. DTSC will continue to monitor and review any media coverage related to environmental issues at the Site throughout the duration of the project. DTSC will continue to monitor and review any media coverage related to environmental issues at the Site throughout the duration of the project.

A Community Survey was mailed on December 18, 2017 to the federal, state, and local elected officials, as well as various city and county agencies to identify concerns regarding the contamination found at the Site. Approximately 981 surveys were mailed out, 23 were sent by email, and 40 surveys were completed and returned, which is a 4.0% return rate. A copy of the Community Survey and the survey results is provided in Appendix A of this Community Profile.

COMMUNITY PROFILE SEDGWICK ELEMENTARY SCHOOL EXPANSION PROJECT 2-4 | P a g e

47.5% of survey respondents stated that they have at least moderate interest in the investigation and cleanup activities at the Site. In addition, 45% of survey respondents stated that they might attend a public meeting for the project if one were held at a convenient time for them. The Community Survey, and the survey results, is included in Appendix A of this Community Profile.

2.5 COMMUNITY CONCERNS
Survey respondents wanted to know the exact location of the Site in relation to their place of residence or business. Furthermore, respondents stated that they have concerns regarding the toxins at the Site, and specifically if those toxins are harmful to the surrounding community.

2.6 SENSITIVE RECEPTORS IN THE LOCAL AREA
No day care centers, schools (primary and secondary), hospitals, or other sensitive communities or receptors were identified within ¼ mile of the Site. No residences are located within ¼ mile of the Site.

COMMUNITY PROFILE SEDGWICK ELEMENTARY SCHOOL EXPANSION PROJECT 3-1 | P a g e

3.0 PUBLIC PARTICIPATION

3.1 RECOMMENDED PUBLIC PARTICIPATION ACTIVITIES
DTSC has determined that based on the responses received to the community survey, the community has 47.5 % interest in the Site activities. Some respondents indicated they have concerns regarding the environmental contamination, but have also expressed confidence that DTSC can oversee the cleanup of the Site. After consideration of community feedback, DTSC recommends the following public participation activities during the investigation and cleanup process.
 A public notice will be published in the newspaper prior to DTSC’s final cleanup decision for the Site. The public notice will announce the Public Comment Period dates for the cleanup for the Site.
 A copy of the draft RAW, the required California Environmental Quality Act document, this Community Profile, and other Site-related documents will be placed in the information repositories listed in Section 3.3 prior to the start of the public comment period.  A Community Update will be prepared to provide historical information, describe the current Site conditions and provide information on the cleanup plan. It will be distributed to the project mailing list that include the City of Cupertino key contacts and the DTSC mandatory mailing list.
 DTSC will contact local community organizations and/or elected officials, as well as other organizations and individuals that survey respondent’s recommended DTSC contact, to set- up a project briefing, if desired. A public meeting, open house session, or community briefing will be considered and may be scheduled if DTSC is requested to conduct one.

With respect to public participation, DTSC will continue to conduct Community Assessments on an as-needed basis throughout the life of the project to monitor the language needs of the local community. The public participation documents for the Site will be provided in English. If subsequent Community Assessments indicate the affected community has translation needs, DTSC will translate all public participation documents to the appropriate languages to ensure those needs are addressed. As investigation and cleanup activities progress, DTSC will review the public participation activities for the Site at various stages of the project. If it is determined that additional public participation activities are necessary, DTSC will implement them as needed.

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3.2 KEY CONTACTS
Kamala Harris
US Senator US Senate 112 Hart Senate Office Building
Washington, DC 20510
Diane Feinstein
US Senator US Senate 112 Hart Senate Office Building
Washington, DC 20510
Jim Beall
State Senator US State Senator 2105 S. Bascom Avenue Ste. 154 Campbell, California 95008
Evan Low
Assembly Member US Assembly Member 20111 Stevens Creek Blvd Ste. 220 Cupertino, California 95014
Savita Vaidhyanathan
Mayor, City of Cupertino Cupertino City Council
Cupertino City Hall
10300 Torres Avenue
Cupertino, California 95014
Darcy Paul
Vice Mayor Cupertino City Council
Cupertino City Hall
10300 Torres Avenue
Cupertino, California 95014
Barry Chang
Council Member Cupertino City Council
Cupertino City Hall
10300 Torres Avenue
Cupertino, California 95014
Rod G. Sinks
Council Member Cupertino City Council
Cupertino City Hall
10300 Torres Avenue
Cupertino, California 95014
Steven Scharf
Council Member Cupertino City Council
Cupertino City Hall
10300 Torres Avenue
Cupertino, California 95014
David Brandt
City Manager City of Cupertino
Cupertino City Hall
10300 Torres Avenue
Cupertino, California 95014
City of Cupertino Code Enforcement
Cupertino City Hall
10300 Torres Avenue
Cupertino, California 95014
City of Cupertino Community
Development
Cupertino City Hall
10300 Torres Avenue
Cupertino, California 95014
City of Cupertino Environment &
Sustainability
Cupertino City Hall
10300 Torres Avenue
Cupertino, California 95014
City of Cupertino Public Works
Cupertino City Hall
10300 Torres Avenue
Cupertino, California 95014
Jose Luevano
Project Manager
Site Mitigation and Brownfields Reuse
Program
Department Toxic Substances Control
8800 Cal Center Drive
Sacramento, California 95826
Tammy Pickens
Public Participation Specialist
Public Participation Branch
Department Toxic Substances Control
8800 Cal Center Drive
Sacramento, California 95826

COMMUNITY PROFILE SEDGWICK EXPANSION PROJECT
3-3 | P a g e
Abbott Dutton
Public Information Officer
Office of Communications
Department Toxic Substances Control
1001 I Street, 22nd Floor
Sacramento, California 95812

3.3 INFORMATION REPOSITORIES
To facilitate community access to key project documents and information, a local information repository will be established and the project Administrative Record (AR) will be made available to the public. The location of the local information repository is listed below, as well as the location of the DTSC Sacramento Regional Office, which is the storage location of the project AR. The repository will include copies of key technical documents, the community profile, fact sheets, and other Site-related documents as they are developed and approved.

Cupertino Library
10800 Torres Avenue
Cupertino, California 95014
(408) 446-1677; Call for hours
DTSC – Sacramento Regional Office
8800 Cal Center Drive
Sacramento, California 95826
(916) 255-3758, Call for an appointment

Cupertino Union School District, District Office
1309 South Mary Avenue, Suite #150
Sunnyvale, California 94087
Contact: Travis Kirk, Director - Facility Modernization (408) 252-3000; Open: 8am - 5:00pm (M-F)

Information can also be found online at DTSC’s Envirostor website: www.envirostor.dtsc.ca.gov

3.4 DTSC PROJECT CONTACTS

Tammy Pickens
Public Participation Specialist
Department of Toxic Substances Control
Sacramento Regional Office
Sacramento, California 95826
Phone: (916) 255-3594, 1-866-495-5651
[email protected]

Jose Luevano
Project Manager
Department of Toxic Substances Control
Sacramento Regional Office
Sacramento, California 95826
Phone: (916) 255-3577
[email protected]

Appendix A Community Cover Letter, Survey Results Appendix A
Appendix A

Community Cover Letter and Survey Results

Appendix A Community Cover Letter, Survey Results Appendix A

Printed on Recycled Paper

Appendix A Community Cover Letter, Survey Results Appendix A

Appendix A Community Cover Letter, Survey Results Appendix A
Printed on Recycled Paper

Appendix B Site Location Map

Appendix B

Appendix B
Site Location Map

Appendix B Site Location Map
Appendix B

APPENDIX F

DTSC COMMUNITY UPDATE

Cal/EPA
State of California

PROPOSED CLEANUP PLAN FOR THE

CUPERTINO UNION SCHOOL DISTRICT
DTSC invites you to review and comment on the draft Removal Action Workplan (RAW) also called draft cleanup plan for of the Cupertino Union School District (District) expansion property located at 10480 Finch Avenue in Cupertino, California 95014 (Site). The Site is located near the exiting Sedgwick Elementary School.

An environmental investigation found high levels of lead and chlordane (a commonly used pesticide chemical) in the soil.

March 23, 2018 - April 23, 2018
DTSC will accept public
comments on the draft RAW
for the Site during the public
comment period of
March 23, 2018 – April 23, 2018.

All comments must be received
by April 23, 2018 and sent to:

Jose Luevano
DTSC Project Manager
8800 Cal Center Drive
Sacramento, California 95826
(916) 255-3577
[email protected]
March 2018
Public Comment Period

SITE HISTORY AND INVESTIGATIONS
The Site consists of 1.48 acres of land that has been used for agricultural purposes from 1939 till 1956 and
used as residential property since 1956. A 500-gallon
gasoline underground storage tank was removed from
the Site in 1996. A house and workshop remains on the
property and will be removed immediately following the
cleanup.

An environmental investigation conducted in January
2016, found high levels of lead and chlordane (a
commonly used pesticide chemical) in the soil on
the northern, western and southeastern sides of the
residential structure and on the western side of the
workshop. The Site is being cleaned up to protect
human health and the environment, and to prepare the
Site for school construction.

PROPOSED CLEANUP OPTIONS
The following four options were considered for the Site:

Alternative 1 – No Action
Alternative 2 – Excavation and Offsite Disposal
Alternative 3 – Treatment
Alternative 4 – Engineering and Institutional Controls

PREFERRED CLEANUP ALTERNATIVE
The preferred cleanup alternative selected is Alternative 2; Excavation and Offsite Disposal. This alternative
would effectively reduce the contamination at the Site
by removing the contaminated soil concentrations
above the selected unrestricted land use levels. If this alternative is approved, approximately 300 cubic yards
of contaminated soil would be excavated and disposed
at a permitted offsite disposal facility. Clean fi ll material may be brought to the Site to backfi ll excavated areas.

SAFETY & DUST CONTROL
Large equipment, such as excavators and backhoes, will
be used to excavate and stockpile the contaminated
soil. Large soil transfer trucks will be used to haul
contaminated soil to the off-site disposal facilities. The following actions will be implemented during the soil
cleanup process to ensure public safety and minimize
dust:

The staging area will be fenced to restrict access;
Stockpiled soil will be covered with tarps or
other protective sheeting;
Water spray will be used to control dust
generation;
Monitoring of the dust generated during the soil
remediation activities will be conducted.;Tarps or
other suitable enclosures will be used on trucks
hauling the excavated soil.

SOIL REMOVAL AND TRUCK ROUTE
Proposed remedial activities will occur between
the hours of 7 A.M.to 5 P .M., Monday - Friday.

Approximately 20 truckloads will be required to
transport the 300 cubic yards of contaminated offsite
to a State-licensed disposal facility. The trucks will be operated by a licensed hazardous waste trucking
contractor. Loaded trucks will exit from the Site’s
northeast gate and turn left on Phil Lane; head west of Phil Lane; turn right onto Miller Avenue; continue onto North Wolfe Road; use right lane to take Interstate I-
280 S onramp; then merge onto I-280 N.

CALIFORNIA ENVIRONMENTAL

QUALITY ACT
Based on the conditions of the Site and the proposed
cleanup alternative, DTSC has determined the response
action qualifi es for a Class 30 Categorical Exemption
pursuant to California Code of Regulations, title
14, section 15330, and intends to issue a Notice of
Exemption (NOE) when the fi nal Removal Action
Workplan (RAW) is approved to comply with the
California Environmental Quality Act (CEQA)
requirements. The draft NOE will be made available for public review, along with other supporting documents in the information repositories.

NEXT STEPS
DTSC will review and consider comments received
during the public comment period before making a
•
•
•
•
fi nal decision to approve, modify or deny the draft RAW . If comments are received, DTSC will prepare a Response to Comments at the completion of the public comment period. Anyone who submits comments will receive a copy of the Response to Comments document, in addition, a copy will be placed in the information repositories listed below.

INFORMATION REPOSITORIES
You may review the draft RAW and other Site-related documents at the following places:

Cupertino Union School District, District Offi ce
1309 South Mary Avenue, Suite #150
Sunnyvale, California 94087
Contact: Travis Kirk, Director – Facility Modernization (408) 252-3000; Open: 8am – 5:00pm (M-F)
Cupertino Library
10800 Torres Avenue
Cupertino, California 95014
(408) 446-1677; Call for hours
DTSC – Sacramento Regional Offi ce
8800 Cal Center Drive
Sacramento, California 95826
(916) 255-3758; Call for appointment
Site documents are also available on-line at: www.envirostor.dtsc.ca.gov.

At the webpag
e search bar, type in Sedgewick. The “Sites/Facilities” information will appear. Click on “View Information”, the summary page for “Sedgewick Elementary School Expansion Project” will appear. Click on “Site Facility Docs”, where you can access project related documents.

DTSC CONTACT INFORMATION
The following individuals may be contacted with any questions or concerns you may have regarding the project:

Jose Luevano, Project Manager
(916) 255-3577
[email protected]
Tammy Pickens, Public Participation Specialist
(916) 255-3594, 1-866-495-5651
[email protected]
Abbott Dutton, Public Information Offi cer
(916) 324-2997
[email protected]

APPENDIX G

HEALTH & SAFETY PLAN
Cupertino Union School District
Project No. 1601-3361

Appendix G - HSP
G-1

APPENDIX G

HEALTH & SAFETY PLAN

Project Title: Removal Action Workplan (RAW) for the Sedgwick Elementary School Expansion Project.

Project Address: 1 0480 Finch Avenue, Cupertino, Santa Clara County, California.

Project Supervisor: Jerome K. Summerlin, C.E.G, C.Hg. Cell Phone: (805) 218-0109 Project Manager: Alan J. Klein, R.E.P.A, C.P.E.S.C. Cell Phone: (916) 947-4831 Site Safety Officer: Alan Churchill, P.G. Cell Phone: (916) 952-5421 Office Phone: (916) 333-5920 (Sacramento Office)

INTRODUCTION
The purpose of this Site Health and Safety Plan (HSP) is to establish requirements for protecting the health and safety of site workers for the above- referenced project. The HSP contains safety information, instructions, and procedures. The HSP will be modified and/or amended when circumstances or conditions develop that are beyond the scope of this plan.

This HSP was prepared to comply with the California Occupational Safety and Health Administration (Cal/OSHA) Hazardous Waste Operations and Emergency Response Standard – Title 8, California code of Regulations (CCR) Section 5192. Each contractor is solely responsible for the health and safety of their own employees.

The planned remedial action (RA) activities including soil excavation and off-site disposal and confirmation soil sampling are anticipated to last approximately one month.

PROJECT DESCRIPTION
The District purchased the Project Site in 2017 as part of the future expansion of Sedgwick Elementary School. At this time, no specific plans have been developed for improving the property. However, based on chemicals of concern (COCs) identified in surficial soil at the Project Site above regulatory screening levels, the District is implementing soil cleanup activities under the oversight of California Department of Toxic Substances Control (DTSC). The COCs are identified to be chlordane (pesticide) and lead.

BACKGROUND
Padre completed a Preliminary Environmental Assessment (PEA) for the Project Site dated September 2015 and a Supplemental Site Investigation (SSI) dated January 2016. The PEA and SSI identified organochlorine pesticides (OCPs) and lead as COCs in soil requiring a response action. The selected response action for the COCs is excavation and off-site disposal at a licensed landfill facility. Based on established remedial cleanup goals (CGs), approximately 300 cubic yards of impacted soil will be excavated, chemically characterized, transported, and disposed of at an appropriate disposal facility.

Cupertino Union School District
Project No. 1601-3361

Appendix G - HSP
G-2

SITE SAFETY OFFICER
The designated site safety officer (SSO) for Padre Associates, Inc., and is responsible for the health and safety for Padre Personnel and site visitors.

The SSO is an individual who is responsible to the employer and has the authority, training, experience, and knowledge necessary to implement the Site H&SP and verify compliance with applicable safety and health requirements. The SSO must verify that all on- site personnel are qualified, trained and prepared to implement the H&SP. Before the start of each day’s work the SSO will hold a safety meeting. The day’s schedule of work and safe work practices will be discussed in the safety meetings.

Removal Contractor SSO
The removal contractor must appoint an SSO for the project who will be responsible for the health and safety for all contractor personnel and subcontractors. The removal contractor will be responsible for compliance with all applicable federal, state, and local laws and guidelines.

The SSO is an individual who is responsible to the employer and has the authority, training, experience, and knowledge necessary to implement the Site H&SP and verify compliance with applicable safety and health requirements. The SSO must verify that all on- site personnel are qualified, trained and prepared to implement the H&SP. Before the start of each day’s work the SSO will hold a safety meeting. The day’s schedule of work and safe work practices will be discussed in the safety meetings.

The removal contractor SSO has the authority to suspend work in the area of the Project Site where the provisions of the H&SP and/or RAW are not being implemented. The removal contractor SSO will report to the contractor’s supervisor and to Padre’s SSO.

The organization chart for the removal action is presented on Plate G-1: Organization Chart.

Project Supervisor:

JEROME K. SUMMERLIN, C.E.G., C.Hg.
(805) 218-0109
Site Safety Officer:

ALAN CHURCHILL, P.G.
(916) 952-5421
Removal Contractor:

Removal Contractor:

REMOVAL ACTION
Cupertino Unified School District
Sedgwick Elementary Expansion Project
Cupertino, California
SITE

VISITORS
Project Manager:

ALAN J. KLEIN, R.E.P.A., C.E.P.S.C.
(916) 947-4831
Field Personnel:

PADRE ASSOCIATES, INC.

Site Safety Officer:

REMOVAL

CONTRACTOR PADRE STAFF
FIELD

PERSONNEL
Removal Contractor:

SUB-

CONTRACTORS

PROJECT

MANAGER
PADRE ASSOCIATES, INC. PADRE ASSOCIATES, INC.
associates, inc.

ENGINEERS, GEOLOGISTS &

ENVIRONMENTAL SCIENTISTS
AJK
DR. BY
AC
APP. BYORGANIZATION CHART
DATE
PROJECT NO.

PLATE G-1
3/12/18 1601-3361
Cupertino Union School District
Project No. 1601-3361

Appendix G - HSP
G-4

HSP ORGANIZATION
The following personnel are designated to carry out the stated job functions pertaining to the site activities. All site personnel have read this safety plan and are familiar with its provisions.

Name Signature
Project Manager:

Site Safety Officer:

Field Personnel:

Field Personnel:

Field Personnel:

Field Personnel:

Field Personnel:

Field Personnel:

Field Personnel:

Field Personnel:

Work was accomplished in accordance with the Site Safety Plan, with the following exceptions:

Site Safety Officer:

Date:
(RETURN ORIGINAL COPY TO JOB FILE WITH SIGNATURES)
EMERGENCY RESPONSE (DIAL 9-1-1)
Nearest phone located: Within Padre Associates, Inc. vehicle or with Padre staff.

Closest Emergency Facility: Santa Clara Valley Medical Center is located approximately 6 miles east of the Project Site
Address: 751 South Bascom Road
San Jose, California 95128
Phone: (408) 885-5000
Ambulance response time: Approximately 10 minutes
Fire and Police will also be contacted by dialing 911. Ambulance service is to be used in emergencies if the injured person cannot safely be transported by a Padre Associates, Inc., vehicle. When in doubt as to the severity of the situation, call 911.

Cupertino Union School District
Project No. 1601-3361

Appendix G - HSP
G-5

DRIVING DIRECTIONS -
From work area, travel west on Phil Lane (0.2 miles);
Turn right onto Miller Avenue (0.5 miles);
Continue onto N Wolfe Road (0.4 miles);
Use right lane to take the on-ramp to I-280 South (0.2 miles); Merge onto 1-280 S (3.3 miles);
Take Exit 6 for Winchester Blvd (0.2 miles);
Turn left onto Moorpark Avenue (1.1 miles);
Turn right onto S Bascom Avenue (0.1 miles);
Turn right onto Renova Drive (180 feet);
Turn left and arrive at hospital facility.

A map illustrating the driving directions is located at the end of the HSP.

SITE DESCRIPTION
Location: 1 0480 Finch Avenue, Cupertino, California.

Potential Hazards: Soil containing OCPs and lead.

Surrounding Land Use: Residential, elementary school.

Topography: Relatively level.

Weather Conditions: Cool with slight winds anticipated.

PROJECT OBJECTIVE
The objectives of the RA is to m inimize exposure of humans to chemicals of concern (COCs) in soil through the inhalation, dermal absorption, and ingestion exposure pathways. The selected RA remedy combines excavation with offsite disposal for OCPs (primarily chlordane) and lead impacted soil. The planned RA activities are summarized below:
• Excavate approximately 300 cy of soil containing OCPs and lead above risk screening levels;
• Stockpile excavated soil and collect composite soil samples for waste characterization and disposal purposes;
• Collect confirmation soil samples from the excavation areas, and compare confirmation results to established cleanup goals (CGs). If needed, excavate an additional volume(s) of soil until the CGs are met; and
• Load and transport impacted soil (~500 tons) to the appropriate disposal facility.

Cupertino Union School District
Project No. 1601-3361

Appendix G - HSP
G-6

CONTAMINANT CONTROL
The following best management practices (BMPs) will be implemented to prevent the off- site migration of COCs:
• Dust control – Spraying water during earth moving activities, and perimeter fencing with wind/dust screens);
• Air monitoring – at least two downwind (fence line) monitoring locations; • Stockpile management – excavated soil stockpiles will be covered with plastic sheeting during non-work hours;
• Decontamination of excavation equipment, transportation vehicles and personnel prior to leaving the site; and
• Site security (fencing, barriers, postings, etc.).

AGENCY REPRESENTATIVES
Name: Jose Luevano, Project Manager
Agency: CalEPA/DTSC
Program: School Property Evaluation and Cleanup Division Phone Number: (916) 255-3577

SITE SETUP
A safe perimeter will be established at the Project Site. The work area will be restricted to required personnel only. No unauthorized personnel will be allowed within the established safe perimeter, or will be allowed to enter the Project Site. Control boundaries will be marked with caution tape if necessary to maintain the established safe perimeter. The onsite command post will be established at the Padre Associates, Inc. vehicle onsite.

HAZARD EVALUATION
Chemicals Onsite. The following substance(s) are known or suspected to be onsite. The primary hazards of each COC are identified along with their site high concentrations in Table G-1:

Table G-1: Chemicals of Concern (COCs)
Substance Involved Primary Hazard Concentration
Chlordane Ingestion, inhalation and
dermal contact
Highest Concentration
Reported:
13 mg/kg
Lead Ingestion, inhalation and
dermal contact
Highest Concentration
Reported:
310 mg/kg
The nature and sources and/or uses of identified COCs are discussed below:

Cupertino Union School District
Project No. 1601-3361

Appendix G - HSP
G-7
CHLORDANE: Chlordane is a man -made chemical that was used as a pesticide in the United States from 1948 to 1988. From 1983 to 1988, chlordane’s only approved use was to control termites in homes. The pesticide was typically applied to the soil around the foundations of buildings with wood components.

LEAD: Lead is a heavy, low melting, bluish-gray metal that occurs naturally in the Earth's crust; however, it is rarely found naturally as a metal. It is usually found combined with two or more other elements to form lead compounds. Metallic lead is resistant to corrosion (i.e., not easily attacked by air or water). When exposed to air or water, thin films of lead compounds are formed that protect the metal from further attack. Lead is easily molded and shaped and can be combined with other metals to form alloys. Lead and lead alloys are commonly found in pipes, storage batteries, weights, shot and ammunition, cable covers, and sheets used to shield us from radiation. The largest use for lead is in storage batteries in cars and other vehicles. Lead compounds are used as a pigment in paints, dyes, and ceramic glazes and in caulk. The amount of lead used in these product s has been reduced in recent years to minimize lead’s harmful effect on people and animals.

Tetraethyl lead and tetramethyl lead were once used in the United States as gasoline additives to increase octane rating. However, their use was phased out in the United States in the 1980s, and lead was banned for use in gasoline for motor vehicles beginning January 1, 1996. Lead used in ammunition, which is the largest non-battery end-use, has remained fairly constant in recent years. However, even the use of lead in bullets and shot as well as in fishing sinkers is being reduced because of its harm to the environment.

HEALTH EFFECTS OF CONTAMINANTS
Chemical information sheets for COCs are presented in Appendix G-1. The health effects of identified COCs are discussed below:

CHLORDANE: Technical grade chlordane is toxic to humans by ingestion of contaminated food, skin absorption, and inhalation. Occupational exposure by dermal and inhalation routes may be significant. Chlordane is easily absorbed through the skin. Technical grade chlordane is a stimulant to the central nervous system but its exact mode of action is unknown. The general symptoms are convulsions and tremors followed by depression.

Cycles of excitement and depression may be repeated several times. Other symptoms are liver damage, anorexia and weight loss. The U.S. EPA has determined that chlordane is a probable human carcinogen (B2 classification).

LEAD: The effects of lead are the same whether it enters the body through breathing or ingestion. The main target for lead toxicity is the nervous system, both in adults and children. Long -term exposure of adults to lead at work has resulted in decreased performance in some tests that measure functions of the nervous system. Lead exposure may also cause weakness in fingers, wrists, or ankles. Lead exposure also causes small increases in blood pressure, particularly in middle-aged and older people. Lead exposure may also cause anemia. At high levels of exposure, lead can severely damage the brain and kidneys in adults or children and ultimately cause death. There is no conclusive proof that lead causes cancer (is carcinogenic) in humans. The Department of Health and Human Services (DHHS) has determined that lead and lead compounds are reasonably anticipated Cupertino Union School District
Project No. 1601-3361

Appendix G - HSP
G-8
to be human carcinogens based on limited evidence from studies in humans and sufficient evidence from animal studies, and the EPA has determined that lead is a probable human carcinogen. The International Agency for Research on Cancer (IARC) has determined that inorganic lead is probably carcinogenic to humans. IARC determined that organic lead compounds are not classifiable as to their carcinogenicity in humans based on inadequate evidence from studies in humans and in animals.

PHYSICAL HAZARDS ONSITE
The physical hazards and potential for employee exposure to the hazards (i.e., low, moderate, and high) anticipated during the field investigation are discussed below.

Heavy Equipment. The hazards involved with using heavy equipment (i.e., excavators; backhoes, loaders and trucks) include hazards of pinch points; impact from moving parts; fatigue; and improper operation. The potential hazard to heavy equipment is high for this project.

The following safe practices are to be followed during work around heavy equipment:
• While working onsite, wear reflective/visible safety vests, maintain visual contact with the operator at all times and remain alert.
• Never walk directly behind or to the side of heavy equipment without the operators knowledge;
• All heavy equipment must be fitted with audible back-up alarms as mandated by OSHA;
• Blades, buckets, and other hydraulic systems will be fully lowered and parking brakes engaged whenever equipment is not in use; and
• All non-essential personnel will be kept out of the work areas.

Slips, Trips and Falls . Site activities can pose a variety of slip, trip and fall hazards.

Examples that contribute to slips, trips and falls include uneven ground surfaces and slick or wet surfaces, unstable earth slopes. The Project Site is a relatively level, however removal action activities will consist of a series of shallow excavated trenches. Therefore, the potential for employee exposure to slips, trips and falls is considered moderate to high during work activities.

Safety cones, delineators, and caution tape will be used to mark the boundaries of the excavations.

Overhead and Underground Utilities. Typical site activities such as movement of equipment or intrusive activities such as excavations can present the risk of contact with overhead or underground utilities. Underground Services Alert will be contacted to mark all underground facilities in the vicinity of intrusive activities. There are numerous underground utilities (water, electric, natural gas, etc.) that are provided to the Project Site from main lines located in adjacent city streets. All utilities (gas, cable, water, etc.) will be disconnected and capped at street, prior to the start of RA Activities.

Heat Stress. High temperatures, direct sun, use of PPE, and labor-intensive activities may contribute to heat stress. Heat stress can involve a high risk of illness of death. The Project Site is located on the southern Bay Area and experiences cool, mild weather in fall months. Therefore, exposure to heat stress at this site is considered low.

Cupertino Union School District
Project No. 1601-3361

Appendix G - HSP
G-9
Symptoms of heat stress or heat exhaustion include:
• Headaches, dizziness, lightheadedness or fainting;
• Weakness and moist;
• Mood changes such as irritability or confusion;
• Upset stomach or vomiting.

Preventing heat stress while working outdoors includes:
• Know the signs/symptoms of heat stress, and monitor yourself and coworkers; • Drink lots of water; about 1 cup every 15 minutes;
• Take regular breaks away from the sun;
• Wear lightweight, light colored, loose-fitting clothes; • Avoid alcohol, caffeinated drinks, or heavy meals.

Treatment for heat related illness includes:
• Move the worker to a cool shaded area;
• Loosen or remove heavy clothing;
• Provide cool drinking water;
• Fan and mist the person with water:
• Call 911.

Fire and Explosion. Gas or sewer lines can contain hazardous levels of explosive or toxic gases, which may pose a fire risk. The risk of fire on site may also stem from the presence of vegetation, heat and fuel sources from construction equipment and site vehicles, or from the presence of combustible gases or vapors in contaminated soil and/or wells. The potential exposure to fire and explosion hazards is considered low, due to the nature and location of the work.

Traffic Hazards. Work activities along roadways, parking areas, and entrance and exit areas create exposure to traffic hazards. The Project Site consist of a large residential property that is fenced off to public traffic. Therefore, the potential exposure to traffic hazards is considered low.

Biological Hazards Onsite. During field activities at the Project Site, a wide variety of insects, including bees, ticks and spiders may be encountered. Stings from bees may cause serious allergic reactions in certain individuals. Ticks are parasites that feed on the blood of an animal/human host and can carry several severe diseases, causing fever and pain for several days and even brain damage. Poisonous snakes or spiders may also be encountered. Skin contact with certain plants (i.e., poison oak and poison ivy) may cause severe reactions. However, due to the lack of vegetation at the work area, the potential exposure to biological hazards is considered low.

ORGANIZATION OF FIELD ACTIVITIES
Field activities will be conducted in three clearly marked zones identified as 1) Exclusion Zone; 2) Decontamination Zone; and 3) Support Zone. Only essential and qualified personnel will be allowed to enter the exclusion and decontamination zones. All site visitors will report to the Command Post Supervisor at the designated area located in the support zone. The designated work zones are illustrated on Plate G-2.

Cupertino Union School District
Project No. 1601-3361

Appendix G - HSP
G-10

GENERAL SAFETY RULES

1. There will be no eating, drinking, or smoking within the safe perimeter set up.

2. Fire extinguishers will be onsite on or near the contractor’s vehicle(s).

3. A first aid kit is located at the onsite command post.

WORKSHOP

SINGLE-ROOM

DWELLING

OVERHANG

OVERHANG

RESIDENCE

PHIL LANE

SOIL STOCKPILE

AREA TRUCK LOADING
AREA

INGRESS
EGRESS

TRUCK INSPECTION
AREA
DECON
(WORKERS)
DECON
(EQUIPMENT)

SUPPORT ZONEPROJECT SITE BOUNDARY

EXCLUSION ZONE BOUNDARY

ESTIMATED EXTENT OF
COCs

TRUCK ROUTE
associates, inc.

ENGINEERS, GEOLOGISTS &

ENVIRONMENTAL SCIENTISTS
PLATE G-2
DR. BY
AC
APP. BYWORK ZONES
DATE
PROJECT NO.
3/12/18AJK 1601-3361
Cupertino Union School District
Project No. 1601-3361

Appendix G - HSP
G-12

PERSONAL PROTECTIVE EQUIPMENT
On the basis of the evaluation of potential hazards, the level of protection deemed appropriate for this site is Level D. Dust monitoring will be conducted to ensure site worker safety, and increased dust control measures will be implemented when monitoring levels indicate levels within 50% of the permissible exposure level for an 8- hour work day. Level D typically includes the following:
• hard hat;
• steel toe and shank boots;
• safety glasses or goggles;
• appropriate safety gloves (latex, rubber, etc.); and
• Long sleeve shirt and pants.

DECONTAMINATION PROCEDURES
Personnel Decontamination. In recognition of the increased risk to workers of physical injury and exposure to chemical contaminants, an exclusion zone will be set up at the Project Site.

All personnel entering the exclusion zone will wear appropriate PPE for the particular task. Upon leaving the designated exclusion zone, all personnel must undergo appropriate decontamination.

The nature and extent of decontamination will be decided by the site health and safety officer and will depend on the level of PPE used and the extent of contamination. Contamination avoidance procedures shall be practiced at all times.

Level D - Decontamination. For Level D PPE work, the following personnel decontamination procedures must be observed by workers prior to rest breaks and upon leaving the exclusion zone:

1. Remove gross contamination from tools, monitoring equipment, boots, etc., prior to leaving the work site, using water, paper towels, Handi-Wipes®, etc.

2. Either completely decontaminate solid equipment at the work site using detergent and water (if possible), or wrap equipment in a plastic bag for transport until complete decontamination is possible.

3. Always follow established personnel decontamination procedures and remove contaminated gloves, paper towels, etc. by placing them in a plastic bag and arranging for proper disposal.

4. Wash hands and face (field wash) thoroughly with soap and water before lunch or coffee breaks, and as soon as possible after finishing work for the day.

DISPOSAL OF WASTES DURING FIELD ACTIVITIES
Generated waste solids (gloves, bottles, wrappers, etc.) will be placed in plastic trash bag and removed from the Project Site at the end of each day.

Excavated soil will be temporarily stored on plastic sheeting and covered with plastic sheeting at the end of each work day.

Cupertino Union School District
Project No. 1601-3361

Appendix G - HSP
G-13

ENVIRONMENTAL MONITORING
Meteorological Monitoring
Onsite meteorological instrumentation will be utilized to measure wind velocity and direction. The meteorological instrument will be checked and recorded by the Site Safety Manager at least once and hour, and/or when a noticeable change in wind speed and direction is observed.

Site Dust Control and Air Monitoring
During earth moving operations dust levels will be monitored at the following locations:
• One upwind location;
• One exclusion zone location; and
• Two downwind (fence line) locations.

Dust levels will be monitored using particulate meters (Thermo Scientific PDR 1500 or equivalent). The particulate meters will be operated in data logging mode and used to measure and record real-time airborne dust concentrations. The locations of the meters will be determined each day by the Site Safety Manager, and will be based on the daily prevailing wind direction.

The particulate meters will be checked every 15 to 20 minutes during earth moving operations. In consultation with DTSC this frequency may be change based on site conditions and newly available data. Increased dust control measures would consist of an increased volume and duration of water spraying during excavation and loading activities at the specific location of the activity. Each time the meters are checked, the difference between the average upwind dust concentration, and the average downwind (fence line) dust concentrations, will be compared to the ambient air quality standard of 0.05 milligrams per cubic meter (mg/m 3) (24-hour average for
particles up 10 microns (PM10)). If this standard is exceeded, increased dust control measures will be implemented and the DTSC Project Manager notified.

Site Worker. Dust control measures and monitoring activities will be implemented at the Project Site. Measured total dust levels will be compared to site action levels. Site action levels are based on the Cal -OSHA permissible exposure levels (PELs) for each COC identified in soil at the Project Site. The PEL for total dust is 10 mg/m

3. Therefore, assuming that total dust is
present at 10 mg/m3 in air and contains the maximum concentration of each COC identified at the Project Site, then site worker exposure levels can be calculated as follows:

Exposure Level (mg/m3) = soil concentration (mg/kg) x total dust PEL (mg/m3) 1,000,000 (mg/kg)
The dust exposure levels for each COC are as follows:

Chlordane: 0.00013 mg/m3 = 13 mg/kg x 10 mg/m3
1,000,000 mg/kg
Lead: 0.0031 mg/m3 = 310 mg/kg x 10 mg/m3
1,000,000 mg/kg
Cupertino Union School District
Project No. 1601-3361

Appendix G - HSP
G-14
Comparing the calculated dust exposure levels for each COC to their respective PEL shows that the selected air monitoring action level for the exclusion zone is protective of site worker health.

Air monitoring action levels for site workers are presented in Table G-2.

Table G-2: Air Monitoring Action Levels for Site Workers Chemical of
Concern
Calculated Dust
Exposure Level(a)

CAL/OSHA PEL
Exclusion Zone
Action Level
(50% of PEL)
Fence Line
Action Level (b)
Chlordane 0.00013 mg/m3 0.5 mg/m3 --- ---
Lead 0.0031 mg/m3 0.05 mg/m3 --- ---
Total Dust --- 10 mg/m3 5 mg/m3 0.05 mg/m3
Notes: PEL - permissible exposure limit (8-hour, time-weighted average (TWA)). (a) – Calculated using 10 mg/m3 total dust.
(b) – California ambient air quality standard (24 hour average for PM10).

Based on these conservative calculations and the use of engineering controls, the need for respirators is not anticipated. However, N100 respirators shall be made available onsite should their use be required.

Sensitive Population. The Sedgwick Elementary School is located adjacent and east of the Project Site, and the students are considered a sensitive population. The fence line action level for total dust has been determined to be 0.05 mg/m3. Therefore, assuming that total dust in air (at the fence line) contains the maximum concentration of each COC identified at the Project Site, the sensitive population exposure levels can be calculated as follows:

Exposure Level (mg/m3) = soil concentration (mg/kg) x total dust at fence line (mg/m3) 1,000,000 (mg/kg)
The dust exposure levels for each COC are as follows:

Chlordane: 0.00000065 mg/m3 = 13 mg/kg x 0.05 mg/m3 1,000,000 mg/kg
Lead: 0.000016 mg/m3 = 310 mg/kg x 0.05 mg/m3
1,000,000 mg/kg
For the adjacent sensitive population (students) , the calculated dust exposure levels for each COC were compared to their risk screening level for ambient air. This comparison shows that the fence line action level for total dust is protective of the adjacent sensitive population. Air monitoring action levels for sensitive populations are presented in Table G-3.

Cupertino Union School District
Project No. 1601-3361

Appendix G - HSP
G-15
Table G-3: Air Monitoring Action Levels for Sensitive Populations Chemical of
Concern
Calculated Dust
Exposure Level(a)

Ambient Air
Screening Level
Fence Line
Action Level(d)
Chlordane 0.00000065 mg/m3 0.0000083 mg/m3 (b) ---
Lead 0.000016 mg/m3 0.00015 mg/m3 (c) ---
Total Dust(b) -- -- 0.05 mg/m3

Notes: (a) – Calculated using 0.05 mg/m3 total dust (fence line action level). (b) – ambient air screening level, DTSC HHRA, Note 3.
(c) – ambient air screening level, USEPA Region 9 RSLs. (d) – California ambient air quality standard (24 hour average for PM10).

Based on these conservative calculations, the selected engineering controls are protective of the most sensitive population.

TRAINING AND MEDICAL SURVEILLANCE
All personnel will have 40-hour Hazardous Waste Operations (HAZWOPER) training; and 8-hour annual refresher training as required under 29 CFR 1910.120/8 CCR 5192.

All contractors are responsible for having their own Injury Illness and Prevention Program (IIPP) in accordance with Cal/OSHA regulations in CCR Title 8. The IIPP’s shall include a discussion of sa fety measures to be implemented, including all those in this HSP, to prevent illness and injury to their employees.

All personnel entering the exclusion zone are required to participate in the Medical Surveillance Program in accordance with 29 CFR 1910.120(F)/8 CCR 5192. All field personnel must have completed either a baseline or annual medical monitoring examination with 12 months of the assignment to the Project Site. Only medically qualified personnel, as determined by the examining physician, will be permitted to conduct field activities.

REMOVAL CONTRACTOR REQUIREMENTS
Licenses, Certificates and Registrations
The removal contractor shall have the following licenses, certifications, and registrations:
• California General Engineering A License;
• Hazardous Substances Removal and Remedial Actions Certification; and • Registered Hazardous Waste Hauler (Trucking Contractor).

Cupertino Union School District
Project No. 1601-3361

Appendix G - HSP
G-16
Training Requirements
Contractors will be required to provide equipment operators and helpers who have completed the following:
• Initial 40-hour Hazardous Waste Operations (HAZWOPER) training; • 8- hour annual refresher training as required under 29 CFR 1910.120/8 CCR 5192; • Respiratory Fit Testing and Training;
• First Aid / Cardiopulmonary Resuscitation Training (minimum one person onsite during removal activities).
• DOT required hazardous materials hauler training (Trucking Contractor).

All contractors are responsible for having their own Injury Illness and Prevention Program (IIPP) in accordance with Cal/OSHA regulations in CCR Title 8. The IIPP’s shall include a discussion of safety measures to be implemented, including all those in this HSP, to prevent illness and injury to their employees.

ATTACHMENT G-1

CHEMICAL INFORMATION SHEETS

__________________________________________________________________________________________

_____________________________________

PUBLIC HEALTH STATEMENT

CHLORDANE
CAS#: 12789-03-6
Division of Toxicology May 1994
This Public Health Statement is the summary
chapter from the Toxicological Profile for
Chlordane. It is one in a series of Public Health
Statements about hazardous substances and their
health effects. A shorter version, the ToxFAQs
TM is
also available. This information is important
because this substance may harm you. The effects
of exposure to any hazardous substance depend on
the dose, the duration, how you are exposed,
personal traits and habits, and whether other
chemicals are present. For more information, call
the ATSDR Information Center at 1-888-422-8737.

This Statement was prepared to give you
information about chlordane and to emphasize the
human health effects that may result from exposure
to it. The Environmental Protection Agency (EPA)
has identified 1,350 hazardous waste sites as the
most serious in the nation. These sites comprise the
"National Priorities List" (NPL): Those sites which
are targeted for long-term federal cleanup activities.

Chlordane has been found in at least 176 of the sites
on the NPL. However, the number of NPL sites
evaluated for chlordane is not known. As EPA
evaluates more sites, the number of sites at which
chlordane is found may increase. This information
is important because exposure to chlordane may
cause harmful health effects and because these sites
are potential or actual sources of human exposure to
chlordane.

When a substance is released from a large area,
such as an industrial plant, or from a container, such
as a drum or bottle, it enters the environment. This
release does not always lead to exposure. You can
be exposed to a substance only when you come in
contact with it. You can be exposed by breathing,
eating, drinking, or through skin contact with
substances containing chlordane.

If you are exposed to a substance such as chlordane,
many factors will determine whether harmful health
effects will occur and what the type and severity of
those health effects will be. These factors include
the dose (how much), the duration (how long), the
route or pathway by which you are exposed
(breathing, eating, drinking, or skin contact), the
other chemicals to which you are exposed, and your
individual characteristics such as age, gender,
nutritional status, family traits, life-style, and state of health.

1.1 WHAT IS CHLORDANE?
Chlordane is a man-made chemical that was used as
a pesticide in the United States from 1948 to 1988.

It is sometimes referred to by the trade names
Octachlor
® and Velsicol 1068®. It is a thick liquid
whose color ranges from colorless to amber,
depending on its purity. It may have no smell or a
mild, irritating smell. We do not know what it tastes
like. Chlordane is not a single chemical, but is a
mixture of many related chemicals, of which about
10 are major components. Some of the major
components are trans-chlordane, cis-chlordane,
beta-chlordene, heptachlor, and trans-nonachlor.

Chlordane does not dissolve in water. Therefore,
before it can be used as a spray, it must be placed in
water with emulsifiers (soap-like substances), which
results in a milky-looking mixture.

From 1983 until 1988, chlordane's only approved
use was to control termites in homes. The pesticide
was applied underground around the foundation of
homes. When chlordane is used in the soil around a
DEPARTMENT of HEALTH AND HUMAN SERVICES, Public Health Service

Agency for Toxic Substances and Disease Registry
www.atsdr.cdc.gov/ Telephone: 1-888-422-8737 Fax: 770-488-4178 E-Mail: [email protected]

__________________________________________________________________________________________

PUBLIC HEALTH STATEMENT

CHLORDANE
CAS#: 12789-03-6
Division of Toxicology May 1994
house, it kills termites that come into contact with
it.

Before 1978, chlordane was also used as a pesticide
on agricultural crops, lawns, and gardens and as a
fumigating agent. Because of concerns over cancer
risk, evidence of human exposure and build up in
body fat, persistence in the environment, and danger
to wildlife, the EPA canceled the use of chlordane
on food crops and phased out other above-ground
uses over the next 5 years. In 1988, when the EPA
canceled chlordane's use for controlling termites, all
approved use of chlordane in the United States
stopped. Manufacture for export continues.

1.2 WHAT HAPPENS TO CHLORDANE

WHEN IT ENTERS THE
ENVIRONMENT?
When used as a pesticide on crops, on lawns and
gardens, and to control termites in houses,
chlordane enters the environment. Although it is no
longer used in the United States, it may be used in
other countries. In soil, it attaches strongly to
particles in the upper layers of soil and is unlikely to enter into groundwater. It is not known whether
chlordane breaks down in most soils. If breakdown
occurs, it is very slow. Chlordane is known to
remain in some soils for over 20 years. Persistence
is greater in heavy, clayey or organic soil than in
sandy soil. Most chlordane is lost from soil by
evaporation. Evaporation is more rapid from light,
sandy soils than from heavy soils. Half of the
chlordane applied to the soil surface may evaporate
in 2 to 3 days. Evaporation is much slower after
chlordane penetrates into the soil. In water, some
chlordane attaches strongly to sediment and
particles in the water column and some is lost by
evaporation. It is not known whether much
breakdown of chlordane occurs in water or in
sediment. Chlordane breaks down in the atmosphere
by reacting with light and with some chemicals in
the atmosphere. However, it is sufficiently long
lived that it may travel long distances and be
deposited on land or in water far from its source.

Chlordane or the chemicals that chlordane changes
into accumulate in fish, birds, and mammals.

Chlordane stays in the environment for many years
and is still found in food, air, water, and soil.

Chlordane is still commonly found in some form in
the fat of fish, birds, mammals, and almost all
humans.

1.3 HOW MIGHT I BE EXPOSED TO
CHLORDANE?
Everyone in the United States has been exposed to
low levels of chlordane. A more relevant question is
whether or not you may have been exposed to high
levels of chlordane. Before its ban in 1988, you
might have been exposed to high levels of
chlordane if you worked in the manufacture,
formulation, or application of chlordane. Therefore,
farmers and lawn-care workers may have been
exposed to chlordane before 1978, and pest control
workers may have been exposed to chlordane
before 1988 by skin contact and breathing dust and
vapor. A national survey conducted from 1980 to
1983 estimated that 3,732 workers were potentially
exposed to chlordane in the United States. This
number of potentially exposed workers should have
decreased after chlordane's use was banned in the
United States. However, the ban on chlordane did
not eliminate it from your environment, and some
of your opportunities for exposure to chlordane
continue.

DEPARTMENT of HEALTH AND HUMAN SERVICES, Public Health Service

Agency for Toxic Substances and Disease Registry
www.atsdr.cdc.gov/ Telephone: 1-888-422-8737 Fax: 770-488-4178 E-Mail: [email protected]

__________________________________________________________________________________________

PUBLIC HEALTH STATEMENT

CHLORDANE
CAS#: 12789-03-6
Division of Toxicology May 1994
Today, people receive the highest exposure to
chlordane from living in homes that were treated
with chlordane for termites. Chlordane may be
found in the air in these homes for many years after
treatment. Houses in the deep south and southwest
were most commonly treated. However, chlordane
use extended from the lower New England States
south and west to California. Houses built since
1988 have not been treated with chlordane for
termite control. You can determine if your home
was treated with chlordane by examining your
records or contacting your termite treatment service.

Over 50 million persons have lived in chlordane-
treated homes. Indoor air in the living spaces of
treated homes have been found to contain average
levels of between 0.00003 and 0.002 milligram
(mg) of chlordane in a cubic meter of air (mg/m³).

However, levels as high as 0.06 mg/m³ have been
measured in the living areas of these homes. Even
higher levels are found in basements and crawl
spaces.

The most common source of chlordane exposure is
from ingesting chlordane- contaminated food.

Chlordane remains in the food supply because much
of the farmland was treated with chlordane in the
1960s and 1970s, and it remains in some soil for
over 20 years. However, since chlordane has been
banned, the levels in soils would be expected to
decrease with the passage of time. Chlordane may
also be found in fish and shellfish caught in
chlordane-contaminated waters. If you are in doubt
about whether a lake or river is contaminated, call
your local Game and Fish or Health departments.

Chlordane is almost never detected in drinking
water. A survey conducted by the Food and Drug
Administration (FDA) determined daily intake of
chlordane from food to be 0.0013 microgram per
kilogram of body weight (µg/kg) for infants and

0.0005-0.0015 µg/kg for teenagers and adults (a
microgram is one thousandth of a milligram). The
average adult would, therefore, consume about 0.11
µg of chlordane.

You may come into contact with chlordane while
digging in soil around the foundation of homes
where it was applied to protect the homes against
termites. Soil may also be contaminated with
chlordane around certain NPL hazardous waste
sites. Chlordane has been found at 176 of 1,350
hazardous waste sites on the NPL in the United
States. The highest level of chlordane found in soil
near an NPL site was 344 ppm. People may be
exposed to chlordane at these sites by breathing low
levels of chlordane volatilizing from the soil or
from touching the soil. Levels of chlordane found in
groundwater near NPL sites containing chlordane
ranged from 0.02 to 830 parts of chlordane per
billion parts of water (ppb).

Finally, some chlordane may be left over from pre-
ban days. Old containers of material thought to
contain chlordane should be disposed of carefully
and contact with the skin and breathing vapors
should be avoided.

1.4 HOW CAN CHLORDANE ENTER AND
LEAVE MY BODY?
Chlordane can enter the body through the skin if
skin contact occurs with contaminated soils,
through the lungs if breathed in with contaminated
air, and through the digestive tract if swallowed.

Uptake through the skin and digestive tract
increases if chlordane is in an oily mixture, which
might occur at hazardous waste sites. The
importance of each of these ways for chlordane to
DEPARTMENT of HEALTH AND HUMAN SERVICES, Public Health Service

Agency for Toxic Substances and Disease Registry
www.atsdr.cdc.gov/ Telephone: 1-888-422-8737 Fax: 770-488-4178 E-Mail: [email protected]

__________________________________________________________________________________________

PUBLIC HEALTH STATEMENT

CHLORDANE
CAS#: 12789-03-6
Division of Toxicology May 1994
enter the body depends on the kind of exposure. For
example, people living in houses that have been
treated with chlordane will be exposed mostly by
breathing the vapor in the air. Workers who sprayed
chlordane as a pesticide were exposed mostly by
breathing the compound in the air and by contact
with the skin. Other people may be exposed to small
quantities by eating food or drinking water that
contains chlordane. People at or near waste sites
may be exposed by touching chlordane in the soil,
by breathing chlordane that evaporates into the air,
by drinking water that contains chlordane or by
eating contaminated fish or crops. The amount of
chlordane that enters the body depends on the
amount in air, food, or water, and the length of time
a person is exposed to it. Most chlordane that enters
the body leaves in a few days, mostly in the feces,
and a much smaller amount leaves in the urine.

Chlordane and its breakdown products may be
stored in body fat, where they cause no bad effects,
unless released from body fat in large amounts. It
may take months or years before the chlordane and
the breakdown products that are stored in fat are
able to leave the body.

1.5 HOW CAN CHLORDANE AFFECT MY
HEALTH?
Most health effects in humans that may be linked to
chlordane exposure are on the nervous system, the
digestive system, and the liver. These effects were
seen mostly in people who swallowed chlordane
mixtures. Large amounts of chlordane taken by
mouth can cause convulsions and death.

Convulsions occurred in a man who had long-term
skin contact with soil containing large amounts of
chlordane. Swallowing small amounts or breathing
air containing high concentrations of chlordane
vapors can cause a variety of nervous system
effects, including headaches, irritation, confusion,
weakness, and vision problems, as well as upset
stomach, vomiting, stomach cramps, diarrhea, and
jaundice.

No harmful effects on health have been confirmed
in studies of workers who made chlordane. One
study found minor changes in liver function in
workers in Japan who used chlordane as a pesticide.

There are indications that chlordane may cause
anemia and other changes in the blood cells, but the
evidence is not very strong.

Animals given high levels of chlordane by mouth
for short periods of time died or had convulsions.

Long-term exposure of animals to chlordane in their
food caused harmful effects in the liver. It is not
known whether chlordane will cause cancer in
humans after long-term exposure. Studies of
workers who made or used chlordane do not link
exposure with cancer, but the information is not
sufficient to know for sure. Mice fed low levels of
chlordane in their food for most of their lifetimes
developed liver cancer. The International Agency
for Research on Cancer (IARC) has determined that
chlordane is not classifiable as to its carcinogenicity to humans. It is not known whether chlordane will
cause reproductive or birth defects in humans.

Studies of workers who made or used chlordane do
not link exposure to the chemical with birth defects,
but there are not enough studies in humans to know
for sure. There is some evidence that animals
exposed before birth or while nursing develop
behavioral effects while growing up.

DEPARTMENT of HEALTH AND HUMAN SERVICES, Public Health Service

Agency for Toxic Substances and Disease Registry
www.atsdr.cdc.gov/ Telephone: 1-888-422-8737 Fax: 770-488-4178 E-Mail: [email protected]

__________________________________________________________________________________________

PUBLIC HEALTH STATEMENT

CHLORDANE
CAS#: 12789-03-6
Division of Toxicology May 1994

1.6 IS THERE A MEDICAL TEST TO

DETERMINE WHETHER I HAVE BEEN
EXPOSED TO CHLORDANE?
Chlordane and its breakdown products (metabolites)
can be measured in human blood, urine, feces, and
breast milk. Tests have shown that most Americans
have low levels of chlordane metabolites in their
body fat. The breakdown products can stay in body
fat for very long periods, so finding them in body
fat or breast milk does not tell how much or how
long ago exposure to chlordane occurred. Not all of
the breakdown products are specific for chlordane.

Finding chlordane and/or breakdown products in
your body also cannot predict what health effects
will occur, if any. Levels in blood and fat can be
tested, although the tests are not routinely available.

1.7 WHAT RECOMMENDATIONS HAS THE

FEDERAL GOVERNMENT MADE TO
PROTECT HUMAN HEALTH?
The EPA guidelines for drinking water suggest that
no more than 60 ppb chlordane should be present in
drinking water that children consume for no longer
than 10 days. Drinking water should contain no
more than 0.5 ppb for children or 2 ppb for adults if
they drink the water for longer periods.

EPA stopped all use of chlordane on food crops,
effective March 1978. Until 1988, EPA permitted
chlordane use for termite control or dipping the
roots or tops of nonfood plants. On April 14, 1988,
however, EPA stopped all sales and commercial use
of chlordane.

The Food and Drug Administration has established
that the levels of chlordane and its breakdown
products in most fruits and vegetables should not be
greater than 300 ppb and in animal fat and fish
should not be greater than 100 ppb.

Federal regulations limit the amount of chlordane
that factories can release into waste water. The EPA
requires industry to report releases or spills of 1
pound or more. A temporary guideline of the
National Research Council indicated that 0.005
mg/m³ should be the maximum amount allowed in
the air of military housing.

The Occupational Safety and Health Administration
(OSHA) regulates chlordane levels in the
workplace. The maximum allowable level in
workplace air is 0.5 mg/m³ for a person who is
exposed for 8 hours per workday and 40 hours per
workweek. The National Institute for Occupational
Health and Safety (NIOSH) also recommends an
exposure limit of 5 mg/m³ for a person exposed to
chlordane in the workplace for 8 hours per workday
and 40 hours per workweek.

1.8 WHERE CAN I GET MORE
INFORMATION?
If you have any more questions or concerns,
please contact your community or state health or
environmental quality department or:

Agency for Toxic Substances and Disease Registry
Division of Toxicology
1600 Clifton Road NE, Mailstop F-32
Atlanta, GA 30333
Information line and technical assistance:

Phone: 888-422-8737
FAX: (770)-488-4178
DEPARTMENT of HEALTH AND HUMAN SERVICES, Public Health Service

Agency for Toxic Substances and Disease Registry
www.atsdr.cdc.gov/ Telephone: 1-888-422-8737 Fax: 770-488-4178 E-Mail: [email protected]

__________________________________________________________________________________________

PUBLIC HEALTH STATEMENT

CHLORDANE
CAS#: 12789-03-6
Division of Toxicology May 1994
ATSDR can also tell you the location of
occupational and environmental health clinics.

These clinics specialize in recognizing, evaluating,
and treating illnesses resulting from exposure to
hazardous substances.

To order toxicological profiles, contact:

National Technical Information Service
5285 Port Royal Road
Springfield, VA 22161
Phone: 800-553-6847 or 703-605-6000
Reference
Agency for Toxic Substances and Disease Registry
(ATSDR). 1994 Toxicological profile for
chlordane. Atlanta, GA: U.S. Department of Health
and Human Services, Public Health Service.

DEPARTMENT of HEALTH AND HUMAN SERVICES, Public Health Service

Agency for Toxic Substances and Disease Registry
www.atsdr.cdc.gov/ Telephone: 1-888-422-8737 Fax: 770-488-4178 E-Mail: [email protected]

__________________________________________________________________________________________

__________________________________________

PUBLIC HEALTH STATEMENT
Lead
CAS#: 7439-92-1
Division of Toxicology and Environmental Medicine August 2007 This Public Health Statement is the summary
chapter from the Toxicological Profile for Lead. It
is one in a series of Public Health Statements about
hazardous substances and their health effects. A
shorter version, the ToxFAQs™, is also available.

This information is important because this
substance may harm you. The effects of exposure
to any hazardous substance depend on the dose, the
duration, how you are exposed, personal traits and
habits, and whether other chemicals are present.

For more information, call the ATSDR Information
Center at 1-800-232-4636.

This public health statement tells you about lead
and the effects of exposure to it.

The Environmental Protection Agency (EPA)
identifies the most serious hazardous waste sites in
the nation. These sites are then placed on the
National Priorities List (NPL) and are targeted for
long-term federal clean-up activities. Lead has been
found in at least 1,272 of the 1,684 current or
former NPL sites. Although the total number of
NPL sites evaluated for this substance is not known,
the possibility exists that the number of sites at
which lead is found may increase in the future as
more sites are evaluated. This information is
important because these sites may be sources of
exposure and exposure to this substance may harm
you.

When a substance is released either from a large
area, such as an industrial plant, or from a container, such as a drum or bottle, it enters the environment.

Such a release does not always lead to exposure.

You can be exposed to a substance only when you
come in contact with it. You may be exposed by
breathing, eating, or drinking the substance, or by
skin contact.

If you are exposed to lead, many factors will
determine whether you will be harmed. These
factors include the dose (how much), the duration
(how long), and how you come in contact with it.

You must also consider any other chemicals you are
exposed to and your age, sex, diet, family traits,
lifestyle, and state of health.

1.1 WHAT IS LEAD?
Lead is a heavy, low melting, bluish-gray metal that
occurs naturally in the Earth's crust. However, it is
rarely found naturally as a metal. It is usually found combined with two or more other elements to form
lead compounds.

Metallic lead is resistant to corrosion (i.e., not easily attacked by air or water). When exposed to air or
water, thin films of lead compounds are formed that
protect the metal from further attack. Lead is easily
molded and shaped. Lead can be combined with
other metals to form alloys. Lead and lead alloys
are commonly found in pipes, storage batteries,
weights, shot and ammunition, cable covers, and
sheets used to shield us from radiation. The largest
use for lead is in storage batteries in cars and other
vehicles.

Lead compounds are used as a pigment in paints,
dyes, and ceramic glazes and in caulk. The amount
of lead used in these products has been reduced in
recent years to minimize lead’s harmful effect on
people and animals. Tetraethyl lead and tetramethyl
lead were once used in the United States as gasoline
DEPARTMENT of HEALTH AND HUMAN SERVICES, Public Health Service

Agency for Toxic Substances and Disease Registry
www.atsdr.cdc.gov/ Telephone: 1-800-232-4636 Fax: 770-488-4178 E-Mail: [email protected]

__________________________________________________________________________________________

PUBLIC HEALTH STATEMENT
Lead
CAS#: 7439-92-1
Division of Toxicology and Environmental Medicine August 2007 additives to increase octane rating. However, their
use was phased out in the United States in the
1980s, and lead was banned for use in gasoline for
motor vehicles beginning January 1, 1996.

Tetraethyl lead may still be used in gasoline for off-
road vehicles and airplanes. It is also still used in a number of developing countries. Lead used in
ammunition, which is the largest non-battery end-
use, has remained fairly constant in recent years.

However, even the use of lead in bullets and shot as
well as in fishing sinkers is being reduced because
of its harm to the environment.

Most lead used by industry comes from mined ores
("primary") or from recycled scrap metal or
batteries ("secondary"). Lead is mined in the
United States, primarily in Alaska and Missouri.

However, most lead today is “secondary” lead
obtained from lead-acid batteries. It is reported that 97% of these batteries are recycled.

1.2 WHAT HAPPENS TO LEAD WHEN IT
ENTERS THE ENVIRONMENT?
Lead occurs naturally in the environment.

However, most of the high levels found throughout
the environment come from human activities.

Environmental levels of lead have increased more
than 1,000-fold over the past three centuries as a
result of human activity. The greatest increase
occurred between the years 1950 and 2000, and
reflected increasing worldwide use of leaded
gasoline. Lead can enter the environment through
releases from mining lead and other metals, and
from factories that make or use lead, lead alloys, or
lead compounds. Lead is released into the air
during burning coal, oil, or waste. Before the use of
leaded gasoline was banned, most of the lead
released into the U.S. environment came from
vehicle exhaust. In 1979, cars released 94.6 million
kilograms (208.1 million pounds) of lead into the
air in the United States. In 1989, when the use of
lead was limited but not banned, cars released only

2.2 million kg (4.8 million pounds) to the air. Since
EPA banned the use of leaded gasoline for highway
transportation in 1996, the amount of lead released
into the air has decreased further. Before the 1950s,
lead was used in pesticides applied to fruit orchards.

Once lead gets into the atmosphere, it may travel
long distances if the lead particles are very small.

Lead is removed from the air by rain and by
particles falling to land or into surface water.

Sources of lead in dust and soil include lead that
falls to the ground from the air, and weathering and
chipping of lead-based paint from buildings,
bridges, and other structures. Landfills may contain
waste from lead ore mining, ammunition
manufacturing, or other industrial activities such as
battery production. Dis posal of lead-containing
products contribute to lead in municipal landfills.

Past uses of lead such as its use in gasoline are a
major contributor to lead in soil, and higher levels
of lead in soil are found near roadways. Most of the
lead in inner city soils comes from old houses with
paint containing lead and previous automotive
exhaust emitted when gasoline contained lead.

Once lead falls onto soil, it sticks strongly to soil
particles and remains in the upper layer of soil.

That is why past uses of lead such as lead in
gasoline, house paint, and pesticides are so
important in the amount of lead found in soil.

Small amounts of lead may enter rivers, lakes, and
streams when soil particles are moved by rainwater.

DEPARTMENT of HEALTH AND HUMAN SERVICES, Public Health Service

Agency for Toxic Substances and Disease Registry
www.atsdr.cdc.gov/ Telephone: 1-800-232-4636 Fax: 770-488-4178 E-Mail: [email protected]

__________________________________________________________________________________________

PUBLIC HEALTH STATEMENT
Lead
CAS#: 7439-92-1
Division of Toxicology and Environmental Medicine August 2007 Small amounts of lead from lead pipe or solder may
be released into water when the water is acidic or
“soft”. Lead may remain stuck to soil particles or
sediment in water for many years. Movement of
lead from soil particles into groundwater is unlikely
unless the rain falling on the soil is acidic or "soft".

Movement of lead from soil will also depend on the
type of lead compound and on the physical and
chemical characteristics of the soil.

Sources of lead in surface water or sediment include
deposits of lead-containing dust from the
atmosphere, waste water from industries that handle
lead (primarily iron and steel industries and lead
producers), urban runoff, and mining piles.

Some lead compounds are changed into other forms
of lead by sunlight, air, and water. However,
elemental lead cannot be broken down.

The levels of lead may build up in plants and
animals from areas where air, water, or soil are
contaminated with lead. If animals eat
contaminated plants or animals, most of the lead
that they eat will pass through their bodies.

1.3 HOW MIGHT I BE EXPOSED TO LEAD?
Lead is commonly found in soil especially near
roadways, older houses, old orchards, mining areas,
industrial sites, near power plants, incinerators,
landfills, and hazardous waste sites. People living
near hazardous waste sites may be exposed to lead
and chemicals that contain lead by breathing air,
drinking water, eating foods, or swallowing dust or
dirt that contain lead. People may be exposed to
lead by eating food or drinking water that contains
lead. Drinking water in houses containing lead
pipes may contain lead, especially if the water is
acidic or “soft”. If one is not certain whether an
older building contains lead pipes, it is best to let
the water run a while before drinking it so that any
lead formed in the pipes can be flushed out. People
living in areas where there are old houses that have
been painted with lead paint may be exposed to
higher levels of lead in dust and soil. Similarly,
people who live near busy highways or on old
orchard land where lead arsenate pesticides were
used in the past may be exposed to higher levels of
lead. People may also be exposed to lead when
they work in jobs where lead is used or have
hobbies in which lead is used, such as making
stained glass.

Foods may contain small amounts of lead.

However, since lead solder is no longer used in
cans, very little lead is found in food. Leafy fresh
vegetables grown in lead-containing soils may have
lead-containing dust on them. Lead may also enter
foods if they are put into improperly glazed pottery
or ceramic dishes and from leaded-crystal
glassware. Illegal whiskey made using stills that
contain lead-soldered parts (such as truck radiators)
may also contain lead. Cigarette smoke may also
contain small amounts of lead. The amount of lead
found in canned foods decreased 87% from 1980 to
1988 in the United States, which indicates that the
chance of exposure to lead in canned food from
lead-soldered containers has been greatly reduced.

Lead-soldered cans are still used in some other
nations. In the most recent studies, lead was not
detectable in most foods and the average dietary
intake of lead was about 1 microgram (a microgram
is a millionth of a gram) per kilogram of body
weight per day. Children may be exposed to lead
DEPARTMENT of HEALTH AND HUMAN SERVICES, Public Health Service

Agency for Toxic Substances and Disease Registry
www.atsdr.cdc.gov/ Telephone: 1-800-232-4636 Fax: 770-488-4178 E-Mail: [email protected]

__________________________________________________________________________________________

PUBLIC HEALTH STATEMENT
Lead
CAS#: 7439-92-1
Division of Toxicology and Environmental Medicine August 2007 by hand-to-mouth contact after exposure to lead-
containing soil or dust.

In general, very little lead is found in lakes, rivers, or groundwater used to supply the public with
drinking water. More than 99% of all publicly
supplied drinking water contains less than

0.005 parts of lead per million parts of water (ppm).

However, the amount of lead taken into your body
through drinking water can be higher in
communities with acidic water supplies. Acidic
water makes it easier for the lead found in pipes,
leaded solder, and brass faucets to be dissolved and
to enter the water we drink. Public water treatment
systems are now required to use control measures to
make water less acidic. Plumbing that contains lead
may be found in public drinking water systems, and
in houses, apartment buildings, and public buildings
that are more than 20 years old. However, as
buildings age, mineral deposits form a coating on
the inside of the water pipes that insulates the water
from lead in the pipe or solder, thus reducing the
amount of lead that can leach into the water. Since
1988, regulations require that drinking water
coolers must not contain lead in parts that come into
contact with drinking water.

Breathing in, or swallowing airborne dust and dirt,
is another way you can be exposed to lead. In 1984,
burning leaded gasoline was the single largest
source of lead emissions. Very little lead in the air
comes from gasoline now because EPA has banned
its use in gasoline for motor vehicles. Other sources
of lead in the air include releases to the air from
industries involved in iron and steel production,
lead-acid-battery manufacturing, and nonferrous
(brass and bronze) foundries. Lead released into air
may also come from burning of solid waste that
contains lead, windblown dust, volcanoes, exhaust
from workroom air, burning or weathering of lead-
painted surfaces, fumes and exhaust from leaded
gasoline, and cigarette smoke.

Skin contact with dust and dirt containing lead
occurs every day. Recent data have shown that
inexpensive cosmetic jewelry pieces sold to the
general public may contain high levels of lead
which may be transferred to the skin through
routine handling. However, not much lead can get
into your body through your skin.

In the home, you or your children may be exposed
to lead if you take some types of home remedy
medicines that contain lead compounds. Lead
compounds are in some non-Western cosmetics,
such as surma and kohl. Some types of hair
colorants, cosmetics, and dyes contain lead acetate.

Read the labels on hair coloring products, use them
with caution, and keep them away from children.

People who are exposed at work are usually
exposed by breathing in air that contains lead
particles. Exposure to lead occurs in many jobs.

People who work in lead smelting and refining
industries, brass/bronze foundries, rubber products
and plastics industries, soldering, steel welding and
cutting operations, battery manufacturing plants,
and lead compound manufacturing industries may
be exposed to lead. Construction and demolition
workers and people who work at municipal waste
incinerators, pottery and ceramics industries,
radiator repair shops, and other industries that use
lead solder may also be exposed. Painters who sand
or scrape old paint may be exposed to lead in dust.

Between 0.5 and 1.5 million workers are exposed to
lead in the workplace. In California alone, more
than 200,000 workers are exposed to lead. Families
of workers may be exposed to higher levels of lead
DEPARTMENT of HEALTH AND HUMAN SERVICES, Public Health Service

Agency for Toxic Substances and Disease Registry
www.atsdr.cdc.gov/ Telephone: 1-800-232-4636 Fax: 770-488-4178 E-Mail: [email protected]

__________________________________________________________________________________________

PUBLIC HEALTH STATEMENT
Lead
CAS#: 7439-92-1
Division of Toxicology and Environmental Medicine August 2007 when workers bring home lead dust on their work
clothes.

You may also be exposed to lead in the home if you
work with stained glass as a hobby, make lead
fishing weights or ammunition, or if you are
involved in home renovation that involves the
removal of old lead-based paint.

1.4 HOW CAN LEAD ENTER AND LEAVE
MY BODY?
Some of the lead that enters your body comes from
breathing in dust or chemicals that contain lead.

Once this lead gets into your lungs, it goes quickly
to other parts of the body in your blood.

Larger particles that are too large to get into your
lungs can be coughed up and swallowed. You may
also swallow lead by eating food and drinking
liquids that contain it. Most of the lead that enters
your body comes through swallowing, even though
very little of the amount you swallow actually
enters your blood and other parts of your body. The
amount that gets into your body from your stomach
partially depends on when you ate your last meal. It
also depends on how old you are and how well the
lead particles you ate dissolved in your stomach
juices. Experiments usi ng adult volunteers showed
that, for adults who had just eaten, the amount of
lead that got into the blood from the stomach was
only about 6% of the total amount taken in. In
adults who had not eaten for a day, about 60–80%
of the lead from the stomach got into their blood. In
general, if adults and children swallow the same
amount of lead, a bigger proportion of the amount
swallowed will enter the blood in children than in
adults. Children absorb about 50% of ingested lead.

Dust and soil that contain lead may get on your
skin, but only a small portion of the lead will pass
through your skin and enter your blood if it is not
washed off. You can, however, accidentally
swallow lead that is on your hands when you eat,
drink, smoke, or apply cosmetics (for example, lip
balm). More lead can pass through skin that has
been damaged (for example, by scrapes, scratches,
and wounds). The only kinds of lead compounds
that easily penetrate the skin are the additives in
leaded gasoline, which is no longer sold to the
general public. Therefore, the general public is not
likely to encounter lead that can enter through the
skin.

Shortly after lead gets into your body, it travels in
the blood to the "soft tissues" and organs (such as
the liver, kidneys, lungs, brain, spleen, muscles, and
heart). After several weeks, most of the lead moves
into your bones and teeth. In adults, about 94% of
the total amount of lead in the body is contained in
the bones and teeth. About 73% of the lead in
children’s bodies is stored in their bones. Some of
the lead can stay in your bones for decades;
however, some lead can leave your bones and
reenter your blood and organs under certain
circumstances (e.g., during pregnancy and periods
of breast feeding, after a bone is broken, and during
advancing age).

Your body does not change lead into any other
form. Once it is taken in and distributed to your
organs, the lead that is not stored in your bones
leaves your body in your urine or your feces. About
99% of the amount of lead taken into the body of an
adult will leave in the waste within a couple of
DEPARTMENT of HEALTH AND HUMAN SERVICES, Public Health Service

Agency for Toxic Substances and Disease Registry
www.atsdr.cdc.gov/ Telephone: 1-800-232-4636 Fax: 770-488-4178 E-Mail: [email protected]

__________________________________________________________________________________________

PUBLIC HEALTH STATEMENT
Lead
CAS#: 7439-92-1
Division of Toxicology and Environmental Medicine August 2007 weeks, but only about 32% of the lead taken into
the body of a child will leave in the waste. Under
conditions of continued exposure, not all of the lead
that enters the body will be eliminated, and this may
result in accumulation of lead in body tissues,
especially bone.

1.5 HOW CAN LEAD AFFECT MY
HEALTH?
Scientists use many tests to protect the public from
harmful effects of toxic chemicals and to find ways
for treating persons who have been harmed.

One way to learn whether a chemical will harm
people is to determine how the body absorbs, uses,
and releases the chemical. For some chemicals,
animal testing may be necessary. Animal testing
may also help identify health effects such as cancer
or birth defects. Without laboratory animals,
scientists would lose a basic method for getting
information needed to make wise decisions that
protect public health. Scientists have the
responsibility to treat research animals with care
and compassion. Scientists must comply with strict
animal care guidelines because laws today protect
the welfare of research animals.

The effects of lead are the same whether it enters
the body through breathing or swallowing. The
main target for lead toxicity is the nervous system,
both in adults and children. Long-term exposure of
adults to lead at work has resulted in decreased
performance in some tests that measure functions of
the nervous system. Lead exposure may also cause
weakness in fingers, wrists, or ankles. Lead
exposure also causes small increases in blood
pressure, particularly in middle-aged and older
people. Lead exposure may also cause anemia. At
high levels of exposure, lead can severely damage
the brain and kidneys in adults or children and
ultimately cause death. In pregnant women, high
levels of exposure to lead may cause miscarriage.

High-level exposure in men can damage the organs
responsible for sperm production.

We have no conclusive proof that lead causes
cancer (is carcinogenic) in humans. Kidney tumors
have developed in rats and mice that had been given
large doses of some kind of lead compounds. The
Department of Health and Human Services (DHHS)
has determined that lead and lead compounds are
reasonably anticipated to be human carcinogens
based on limited evidence from studies in humans
and sufficient evidence from animal studies, and the
EPA has determined that lead is a probable human
carcinogen. The International Agency for Research
on Cancer (IARC) has determined that inorganic
lead is probably carcinogenic to humans. IARC
determined that organic lead compounds are not
classifiable as to their carcinogenicity in humans
based on inadequate evidence from studies in
humans and in animals.

1.6 HOW CAN LEAD AFFECT CHILDREN?
This section discusses potential health effects in
humans from exposures during the period from
conception to maturity at 18 years of age.

Studies carried out by the Centers for Disease
Control and Prevention (CDC) show that the levels
of lead in the blood of U.S. children have been
getting lower and lower. Th is result is because lead
DEPARTMENT of HEALTH AND HUMAN SERVICES, Public Health Service

Agency for Toxic Substances and Disease Registry
www.atsdr.cdc.gov/ Telephone: 1-800-232-4636 Fax: 770-488-4178 E-Mail: [email protected]

__________________________________________________________________________________________

PUBLIC HEALTH STATEMENT
Lead
CAS#: 7439-92-1
Division of Toxicology and Environmental Medicine August 2007 is banned from gasoline, residential paint, and
solder used for food cans and water pipes.

However, about 310,000 U.S. children between the
ages of 1 and 5 years are believed to have blood
lead levels equal or greater than 10 μg/dL, the level
targeted for elimination among young children in
the Unites States by 2010.

Children are more vulnerable to lead poisoning than
adults. Children are exposed to lead all through
their lives. They can be exposed to lead in the
womb if their mothers have lead in their bodies.

Babies can swallow lead when they breast feed, or
eat other foods, and drink water that contains lead.

Babies and children can swallow and breathe lead in
dirt, dust, or sand while they play on the floor or
ground. These activities ma ke it easier for children
to be exposed to lead than adults. The dirt or dust
on their hands, toys, and other items may have lead
particles in it. In some cases, children swallow
nonfood items such as paint chips; these may
contain very large amounts of lead, particularly in
and around older houses that were painted with
lead-based paint. The pa int in these houses often
chips off and mixes with dust and dirt. Some old
paint contains as much as 50% lead. Also,
compared with adults, a bigger proportion of the
amount of lead swallowed will enter the blood in
children.

Children are more sensitive to the health effects of
lead than adults. No safe blood lead level in
children has been determined. Lead affects children
in different ways depending on how much lead a
child swallows. A child who swallows large
amounts of lead may develop anemia, kidney
damage, colic (severe “stomach ache”), muscle
weakness, and brain damage, which ultimately can
kill the child. In some cases, the amount of lead in
the child’s body can be lowered by giving the child
certain drugs that help eliminate lead from the body.

If a child swallows smaller amounts of lead, such as
dust containing lead from paint, much less severe
but still important effects on blood, development,
and behavior may occur. In this case, recovery is
likely once the child is removed from the source of
lead exposure, but there is no guarantee that the
child will completely avoid all long-term
consequences of lead exposure. At still lower levels
of exposure, lead can affect a child’s mental and
physical growth. Fetuses exposed to lead in the
womb, because their mothers had a lot of lead in
their bodies, may be born prematurely and have
lower weights at birth. Exposure in the womb, in
infancy, or in early childhood also may slow mental
development and cause lower intelligence later in
childhood. There is evidence that these effects may
persist beyond childhood.

Children with high blood lead levels do not have
specific symptoms. However, health workers can
find out whether a child may have been exposed to
harmful levels of lead by taking a blood sample.

They can also find out how much lead is in a child’s
bones by taking a special type of x-ray of the finger,
knee, or elbow. This type of test, however, is not
routine.

1.7 HOW CAN FAMILIES REDUCE THE
RISK OF EXPOSURE TO LEAD?
If your doctor finds that you have been exposed to
substantial amounts of lead, ask whether your
children might also have been exposed. Your
doctor might need to ask your state health
department to investigate.

DEPARTMENT of HEALTH AND HUMAN SERVICES, Public Health Service

Agency for Toxic Substances and Disease Registry
www.atsdr.cdc.gov/ Telephone: 1-800-232-4636 Fax: 770-488-4178 E-Mail: [email protected]

__________________________________________________________________________________________

PUBLIC HEALTH STATEMENT
Lead
CAS#: 7439-92-1
Division of Toxicology and Environmental Medicine August 2007 The most important way families can lower
exposures to lead is to know about the sources of
lead in their homes and avoid exposure to these
sources. Some homes or day-care facilities may
have more lead in them than others. Families who
live in or visit these places may be exposed to
higher amounts of lead. These include homes built
before 1978 that may have been painted with paint
that contains lead (lead-based paint). If you are
buying a home that was built before 1978, you may
want to know if it contains lead based paint.

Federal government regulations require a person
selling a home to tell the real estate agent or person
buying the home of any known lead-based hazards
on the property. Adding lead to paint is no longer
allowed. If your house was built before 1978, it
may have been painted with lead-based paint. This
lead may still be on walls, floors, ceilings, and
window sills, or on the outside walls of the house.

The paint may have been scraped off by a previous
owner, but paint chips and lead-containing dust may
still be in the yard soil. Decaying, peeling, or
flaking paint can introduce lead into household dust
and the area where this is occurring should be
repainted. If your paint is decaying or your child
has symptoms of lead poisoning, you may want to
have your house tested for lead. In some states,
homeowners can have the paint in their homes
tested for lead by their local health departments.

The National Lead Information Center (1-800-532-
3394) has a listing of approved risk assessors
(people who have met certain criteria and are
qualified to assess the potential risks of a site) and
of approved testing laboratories (for soil, paint, and
dust).

Sanding surfaces painted with lead-based paint or
using heat to peel the paint may cause exposure to
high levels of lead. Many cases of lead poisoning
have resulted from do-it-yourself home renovations.

Therefore, any renovations should be performed by
a licensed contractor who will minimize exposure to
household members. It is important for the area
being renovated to be isolated from the rest of the
house because of lead-containing dust. The federal
government requires that contractors who test for or
remove lead must be certified by the EPA or an
EPA-approved state program. Ask to see
certifications of potential contractors. Your state
health department or environmental protection
division should be able to identify certified
contractors for you. The National Lead Abatement
Council (P.O. Box 535; Olney, MD 20932;
telephone 301-924-5490) can also send you a list of
certified contractors.

Families can lower the possibility of children
swallowing paint chips by discouraging their
children from chewing or putting these painted
surfaces in their mouths and making sure that they
wash their hands often, especially before eating.

Lead can be found in dirt and dust. Areas where
levels of lead in dirt might be especially high are
near old houses, highways, or old orchards. Some
children have the habit of eating dirt (the term for
this activity is pica). Discourage your children from
eating dirt and other hand-to-mouth activity.

Non-Western folk remedies used to treat diarrhea or
other ailments may contain substantial amounts of
lead. Examples of these include: Alarcon,
Ghasard, Alkohl, Greta, Azarcon, Liga, Bali Goli,
Pay-loo-ah, Coral, and Rueda. If you give your
children these substances or if you are pregnant or
nursing, you may expose your children to lead. It is
wise to know the ingredients of any medicines that
you or your children use.

DEPARTMENT of HEALTH AND HUMAN SERVICES, Public Health Service

Agency for Toxic Substances and Disease Registry
www.atsdr.cdc.gov/ Telephone: 1-800-232-4636 Fax: 770-488-4178 E-Mail: [email protected]

__________________________________________________________________________________________

PUBLIC HEALTH STATEMENT
Lead
CAS#: 7439-92-1
Division of Toxicology and Environmental Medicine August 2007 Older homes that have plumbing containing lead
may have higher amounts of lead in drinking water.

Inside plumbing installed before 1930 is most likely
to contain high levels of lead. Copper pipes have
replaced lead pipes in most residential plumbing.

You cannot see, taste, or smell lead in water, and
boiling your water will not get rid of lead. If you
have a water-lead problem, EPA recommends that
anytime water in a particular faucet has not been
used for 6 hours or longer, you should flush your
cold water pipes by running water until it is cold
(5 seconds–2 minutes). Because lead dissolves
more easily in warm water than in cold water, you
should only use cold water for drinking, cooking,
and preparing baby formula. You can contact your
local health department or water supplier to find out
about testing your water for lead. If your water
tests indicate a significant presence of lead, consult
your water supplier or local health department about
possible remedies.

You can bring lead home in the dust on your hands
or clothes if lead is used in the place where you
work. Lead dust is likely to be found in places
where lead is mined or smelted, where car batteries
are made or recycled, where electric cable sheathing
is made, where fine crystal glass is made, or where
certain types of ceramic pottery are made. Pets can
also bring lead into the home in dust or dirt on their
fur or feet if they spend time in places that have
high levels of lead in the soil.

Swallowing of lead in house dust or soil is a very
important exposure pathway for children. This
problem can be reduced in many ways. Regular
hand and face washing to remove lead dusts and
soil, especially before meals, can lower the
possibility that lead on the skin is accidentally
swallowed while eating. Families can lower
exposures to lead by regularly cleaning the home of
dust and tracked in soil. Door mats can help lower
the amount of soil that is tracked into the home;
removing your shoes before entering the home will
also help. Planting grass and shrubs over bare soil
areas in the yard can lower contact that children and
pets may have with soil and the tracking of soil into
the home.

Families whose members are exposed to lead dusts
at work can keep these dusts out of reach of
children by showering and changing clothes before
leaving work, and bagging their work clothes before
they are brought into the home for cleaning. Proper
ventilation and cleaning—during and after hobby
activities, home or auto repair activities, and hair
coloring with products that contain lead—will
decrease the possibility of exposure.

Lead-containing dust may be deposited on plant
surfaces and lead may be taken up in certain edible
plants from the soil by the roots; therefore, home
gardening may also contribute to exposure if the
produce is grown in soils that have high lead
concentrations. Vegetables should be well washed
before eating to remove surface deposits. Certain
hobbies and home or car repair activities like
radiator repair can add lead to the home as well.

These include soldering glass or metal, making
bullets or slugs, or glazing pottery. Some types of
paints and pigments that are used as facial make-up
or hair coloring contain lead. Cosmetics that
contain lead include surma and kohl, which are
popular in certain Asian countries. Read the labels
on hair coloring products, and keep hair dyes that
contain lead acetate away from children. Do not
allow children to touch hair that has been colored
with lead-containing dyes or any surfaces that have
come into contact with these dyes because lead
DEPARTMENT of HEALTH AND HUMAN SERVICES, Public Health Service

Agency for Toxic Substances and Disease Registry
www.atsdr.cdc.gov/ Telephone: 1-800-232-4636 Fax: 770-488-4178 E-Mail: [email protected]

__________________________________________________________________________________________

PUBLIC HEALTH STATEMENT
Lead
CAS#: 7439-92-1
Division of Toxicology and Environmental Medicine August 2007 compounds can rub off onto their hands and be
transferred to their mouths.

It is important that children have proper nutrition
and eat a balanced diet of foods that supply
adequate amounts of vitamins and minerals,
especially calcium and iron. Good nutrition lowers
the amount of swallowed lead that passes to the
bloodstream and also may lower some of the toxic
effects of lead.

1.8 IS THERE A MEDICAL TEST TO

DETERMINE WHETHER I HAVE BEEN
EXPOSED TO LEAD?
The amount of total lead in the blood can be
measured to determine if exposure to lead has
occurred. This test shows if you have been recently
exposed to lead. Lead can be measured in teeth or
bones by x-ray techniques, but these methods are
not widely available. These tests show long-term
exposures to lead. The primary screening method is
measurement of blood lead. Exposure to lead also
can be evaluated by measuring erythrocyte
protoporphyrin (EP) in blood samples. EP is a part
of red blood cells known to increase when the
amount of lead in the blood is high. However, the
EP level is not sensitive enough to identify children
with elevated blood lead levels below about
25 micrograms per deciliter (μg/dL). These tests
usually require special analytical equipment that is
not available in a doctor’s office. However, your
doctor can draw blood samples and send them to
appropriate laboratories for analysis.

1.9 WHAT RECOMMENDATIONS HAS THE

FEDERAL GOVERNMENT MADE TO
PROTECT HUMAN HEALTH?
The federal government develops regulations and
recommendations to protect public health.

Regulations can be enforced by law. The EPA, the
Occupational Safety and Health Administration
(OSHA), and the Food and Drug Administration
(FDA) are some federal agencies that develop
regulations for toxic substances. Recommendations
provide valuable guidelines to protect public health,
but cannot be enforced by law. The Agency for
Toxic Substances and Disease Registry (ATSDR)
and the National Institute for Occupational Safety
and Health (NIOSH) are two federal organizations
that develop recommendations for toxic substances.

Regulations and recommendations can be expressed
as “not-to-exceed” levels, that is, levels of a toxic
substance in air, water, soil, or food that do not
exceed a critical value that is usually based on
levels that affect animals; they are then adjusted to
levels that will help protect humans. Sometimes
these not-to-exceed levels differ among federal
organizations because they used different exposure
times (an 8-hour workday or a 24-hour day),
different animal studies, or other factors.

Recommendations and regulations are also updated
periodically as more information becomes available.

For the most current information, check with the
federal agency or organization that provides it.

Some regulations and recommendations for lead
include the following:

CDC recommends that states develop a plan to find
children who may be exposed to lead and have their
DEPARTMENT of HEALTH AND HUMAN SERVICES, Public Health Service

Agency for Toxic Substances and Disease Registry
www.atsdr.cdc.gov/ Telephone: 1-800-232-4636 Fax: 770-488-4178 E-Mail: [email protected]

__________________________________________________________________________________________

PUBLIC HEALTH STATEMENT
Lead
CAS#: 7439-92-1
Division of Toxicology and Environmental Medicine August 2007 blood tested for lead. CDC recommends that the
states test children:
• at ages 1 and 2 years;
• at ages 3–6 years if they have never
been tested for lead;
• if they receive services from public
assistance programs for the poor
such as Medicaid or the
Supplemental Food Program for
Women, Infants, and Children;
• if they live in a building or
frequently visit a house built before
1950;
• if they visit a home (house or
apartment) built before 1978 that has
been recently remodeled; and/or
• if they have a brother, sister, or
playmate who has had lead
poisoning.

CDC considers children to have an elevated level of
lead if the amount of lead in the blood is at least
10 μg/dL. Many states or local programs provide
intervention to individual children with blood lead
levels equal to or greater than 10 μg/dL. Medical
evaluation and environmental investigation and
remediation should be done for all children with
blood lead levels equal to or greater than 20 μg/dL.

Medical treatment (i.e., chelation therapy) may be
necessary in children if the lead concentration in
blood is higher than 45 μg/dL.

EPA requires that the concentration of lead in air
that the public breathes be no higher than

1.5 micrograms per cubic meter (μg/m
3) averaged
over 3 months. EPA regulations no longer allow
lead in gasoline. The Clean Air Act Amendments
(CAAA) of 1990 banned the sale of leaded gasoline
as of December 31, 1995.

Under the Lead Copper Rule (LCR), EPA requires
testing of public water systems, and if more than
10% of the samples at residences contain lead levels
over 0.015 milligrams per liter (mg/L), actions must
be taken to lower these levels. Testing for lead in
drinking water in schools is not required unless a
school is regulated under a public water system.

The 1988 Lead Contamination Control Act (LCCA)
was created to help reduce lead in drinking water at
schools and daycare centers. The LCCA created
lead monitoring and reporting requirements for
schools, as well as the replacement of fixtures that
contain high levels of lead. However, the
provisions in the LCCA are not enforceable by the
federal government and individual states have the
option to voluntarily comply with these provisions
or create their own.

To help protect small children, the Consumer
Product Safety Commission (CPSC) requires that
the concentration of lead in most paints available
through normal consumer channels be not more
than 0.06%. The Federal Hazardous Substance Act
(FHSA) bans children’s products containing
hazardous amounts of lead.

The Department of Housing and Urban
Development (HUD) develops recommendations
and regulations to prevent exposure to lead. HUD
requires that federally funded housing and
renovations, Public and Indian housing be tested for
DEPARTMENT of HEALTH AND HUMAN SERVICES, Public Health Service

Agency for Toxic Substances and Disease Registry
www.atsdr.cdc.gov/ Telephone: 1-800-232-4636 Fax: 770-488-4178 E-Mail: [email protected]

__________________________________________________________________________________________

PUBLIC HEALTH STATEMENT
Lead
CAS#: 7439-92-1
Division of Toxicology and Environmental Medicine August 2007 lead-based paint hazards and that such hazards be
fixed by covering the paint or removing it. When
determining whether lead-based paint applied to
interior or exterior painted surfaces of dwellings
should be removed, the standard used by EPA and
HUD is that paint with a lead concentration equal to
or greater than 1.0 milligram per square centimeter
(mg/cm
2) of surface area should be removed or
otherwise treated. HUD is carrying out
demonstration projects to determine the best ways
of covering or removing lead-based paint in
housing.

EPA has developed standards for lead-paint
hazards, lead in dust, and lead in soil. To educate
parents, homeowners, and tenants about lead
hazards, lead poisoning prevention in the home, and
the lead abatement process, EPA has published
several general information pamphlets. Copies of
these pamphlets can be obtained from the National
Lead Information Center or from various Internet
sites, including http://www.epa.gov/opptintr/lead.

OSHA regulations limit the concentration of lead in
workroom air to 50 μg/m
3 for an 8-hour workday.

If a worker has a blood lead level of 50 μg/dL or
higher, then OSHA requires that the worker be
removed from the workroom where lead exposure is
occurring.

FDA includes lead on its list of poisonous and
deleterious substances. FDA considers foods
packaged in cans containing lead solders to be
unsafe. Tin-coated lead foil has been used as a
covering applied over the cork and neck areas of
wine bottles for decorative purposes and to prevent
insect infestations. Because it can be reasonably
expected that lead could become a component of the
wine, the use of such foil is also a violation of the
Federal Food, Drug, and Cosmetic Act. FDA has
reviewed several direct human food ingredients
(i.e., food dyes) and has determined them to be
“generally recognized as safe” when used in
accordance with current good manufacturing
practices. Some of these ingredients contain
allowable lead concentrations that range from 0.1 to
10 ppm.

1.10 WHERE CAN I GET MORE
INFORMATION?
If you have any more questions or concerns, please
contact your community or state health or
environmental quality department, or contact
ATSDR at the address and phone number below.

ATSDR can also tell you the location of
occupational and environmental health clinics.

These clinics specialize in recognizing, evaluating,
and treating illnesses that result from exposure to
hazardous substances.

Toxicological profiles are also available on-line at
www.atsdr.cdc.gov and on CD-ROM. You may
request a copy of the ATSDR ToxProfiles
TM
CD-ROM by calling the toll-free information and
technical assistance number at 1-800-CDCINFO
(1-800-232-4636), by e-mail at [email protected],
or by writing to:

DEPARTMENT of HEALTH AND HUMAN SERVICES, Public Health Service

Agency for Toxic Substances and Disease Registry
www.atsdr.cdc.gov/ Telephone: 1-800-232-4636 Fax: 770-488-4178 E-Mail: [email protected]

__________________________________________________________________________________________

PUBLIC HEALTH STATEMENT
Lead
CAS#: 7439-92-1
Division of Toxicology and Environmental Medicine August 2007 Agency for Toxic Substances and Disease Registry
Division of Toxicology and Environmental
Medicine
1600 Clifton Road NE
Mailstop F-32
Atlanta, GA 30333
Fax: 1-770-488-4178
Organizations for-profit may request copies of final
Toxicological Profiles from the following:

National Technical Information Service (NTIS)
5285 Port Royal Road
Springfield, VA 22161
Phone: 1-800-553-6847 or 1-703-605-6000
Web site: http://www.ntis.gov/
DEPARTMENT of HEALTH AND HUMAN SERVICES, Public Health Service

Agency for Toxic Substances and Disease Registry
www.atsdr.cdc.gov/ Telephone: 1-800-232-4636 Fax: 770-488-4178 E-Mail: [email protected]

APPENDIX H

QUALITY ASSURANCE PROJECT PLAN

QUALITY ASSURANCE PROJECT PLAN (QAPP)

FOR

REMOVAL ACTION WORKPLAN

SEDGWICK ELEMENTARY SCHOOL EXPANSION PROJECT

CUPERTINO, SANTA CLARA COUNTY, CALIFORNIA
(SITE CODE: 204271)

Prepared for:

Cupertino Union School District

Prepared by:

Padre Associates, Inc.

August 2017
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TABLE OF CONTENTS
Page

1.0 INTRODUCTION ................................................................................. 1

1.1 Site Background and History ...................................................... 1

2.0 PROJECT DESCRIPTION ................................................................... 1

2.1 Analytical Scope ........................................................................ 2

2.2 Data Use ................................................................................... 2

3.0 PROJECT ORGANIZATION ................................................................ 2

3.1 Project Proponent ...................................................................... 2

3.2 Regulatory Agency .................................................................... 2

3.3 Removal Contractor ................................................................... 3

3.4 Environmental Consultant .......................................................... 3

3.5 Laboratory ................................................................................. 3

4.0 DATA QUALITY OBJECTIVES ............................................................ 3

4.1 Data Quality Objective Process ................................................. 3

4.2 Precision, Accuracy, Representativeness,
Comparability, and Completeness ............................................. 4

4.2.1 Percision ....................................................................... 4

4.2.2 Accuracy ....................................................................... 5

4.2.3 Representativeness ....................................................... 5

5.0 QUALITY CONTROL ELEMENTS ....................................................... 6

5.1 Quality control Procedures ......................................................... 6

5.1.1 Equipment Decontamination.......................................... 6

5.1.2 Standards ...................................................................... 6

5.1.3 Supplies ........................................................................ 6

5.1.4 Holding Time Compliance ............................................. 7

5.1.5 Preventive Maintenance ................................................ 7

5.2 Quality Assurance and Quality Control (QA/QC) Samples ......... 7

5.2.1 Duplicate Sample Collection .......................................... 7

5.2.2 Laboratory Reagent Blanks ........................................... 7

5.2.3 Field Equipment Blanks ................................................. 8

5.2.4 Matrix Spike Samples .................................................... 8

6.0 QUALITY CONTROL ELEMENTS ....................................................... 8

6.1 Field Procedures ....................................................................... 8

6.2 Sample Containers, Preservation, and Holding Times ............... 8

6.3 Sample Handling and Storing .................................................... 9

6.4 Sample Custody ........................................................................ 9

7.0 ANALYTICAL PROCEDURES ............................................................. 9

7.1 Internal Standards ..................................................................... 9

7.2 Method Detection Limits ............................................................ 9

7.3 Laboratory Instrument Calibration .............................................. 10

7.4 Field Instrument Calibration ....................................................... 10

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TABLE OF CONTENTS (continued)
Page

8.0 DATA REPORTING ............................................................................. 10

8.1 Field Data .................................................................................. 10

8.2 Laboratory Data ......................................................................... 11

8.3 Procedures for Data Validation .................................................. 11

8.4 Data Qualifiers ........................................................................... 12

9.0 PERFORMANCE AND SYSTEMS AUDITS ......................................... 12

9.1 Field Performance ..................................................................... 12

9.2 Laboratory Audits ...................................................................... 12

9.3 Reports to Management and Responsibilities ............................ 12

9.4 Correction Action ....................................................................... 12

10.0 REFERENCES .................................................................................... 13

TABLE 1: Reporting Limits and Holding Times for COCs ...................................... 14

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APPENDIX G

QUALITY ASSURANCE PROJECT PLAN (QAPP)
For
Removal Action Workplan
Sedgwick Elementary School Expansion Project
Cupertino, Santa Clara County, California

1.0 INTRODUCTION
This document presents the q uality assurance project plan (QAPP) for the planned remedial action activities to be completed at the Sedgwick Elementary School Expansion Project located at 10480 Finch Avenue in Cupertino, Santa Clara County, California (Project Site).

The QAPP addresses quality assurance (QA) and quality control (QC) policies associated with performing the remedial action at the Project Site. Together with the accompanying Remedial Action Workplan (RAW) this QAPP presents the plan for confirmation sampling, analysis, and data review during the remedial action, which will be performed under the regulatory oversight of the California Department of Toxic Substances Control (DTSC).

The purpose of this QAPP is to identify the methods to be employed to establish technical accuracy, precision, and validity of data that is generated at the Project Site.

1.1 Site Background
The Cupertino Union School District purchased the Project Site in 2017. At this time, no specific plans have been developed for improving the property. However, based on chemicals of concern (COCs) identified in surficial soil at the Project Site above regulatory screening levels, the District is implementing soil cleanup activities under the oversight of California Department of Toxic Subs tances Control (DTSC). The COCs are identified to be chlordane (pesticide) and lead.

Padre completed a Preliminary Environmental Assessment (PEA) for the Project Site dated September 2015 and a Supplemental Site Investigation (SSI) dated January 2016. Th e PEA and SSI i dentified or ganochlorine pesticides (OCPs) and lead as chemicals of concern (COCs) in so il requiring a response action. The selected response action for the COCs is excavation and off -site disposal at a licensed landfill facility. Based on established remedial cleanup goals (CGs), approximately 300 cubic yards of impacted soil will be excavated, chemically characterized, transported, and disposed of at an appropriate disposal facility.

2.0 PROJECT DESCRIPTION
This section presents information concerning the proposed sampling activities, selected analytical parameters, data quality objectives, and the resulting project decisions. The RAW provides specifications for field activities.

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2.1 A nalytical Scope
The planned sampling effort includes the sampling and analyses of soil for the COCs identified during the PEA and SSI. The RAW includes specific procedures for collecting confirmation samples from the onsite areas targeted for excavation of impacted soil. Samples will be analyzed in accordance with USEPA- approved methods presented in the RAW. The target analytes and detection limits for the analyses of soil samples are listed in Table 1.

Analyzed quality control (QC) samples will include field duplicates and equipment rins eate blanks.

Waste characterization and landfill approval will be obtained prior to transporting soil off the Project Site. If detected concentrations of COCs do not exceed the California total threshold limit concentration (TTLC), then the soil will be disposed of as a non-hazardous waste. If detected concentrations of COCs exceed the TTLC, then the soil will be classified as a hazardous waste. The soil sample is then analyzed for the soluble threshold limit concentration (STLC) by the California Waste Extraction Test (WET) or the toxicity characteristic leaching procedure (TCLP), depending on the acceptance criteria of the landfill facility. If detected concentrations of COCs exceed the STLC/TCLP then the soil will be classified as a RCRA - hazardous waste. The values for waste characterization are listed in Table 1.

2.2 Data Use
Decisions will be made based on the data compiled from the sampling and analysis program. The data collected will be used to assess whether the soil containing COCs above their respective cleanup goals have been removed from the Project Site. The Data will be used to determine the need for possible additional excavation of impacted soil. Additionally, the collected data will be used for waste characterization.

3.0 PROJECT ORGANIZATION
This section provides a description of the organizational structure and responsibilities of the individual positions for this project. This description defines the lines of communication and identifies key personnel assigned to various activities for the project.

3.1 Project Proponent
The Cupertino Union School District (District) is the project proponent and is the party with ultimate responsibility for ensuring that the Project Site is safe for future students and school staff. The District will retain a remova l contractor for excavation and transportation of impacted soil to the approved landfill. The District will also retain an environmental consultant to conduct air monitoring and confirmation soil sampling. The soil samples will be analyzed by a State accredited laboratory.

3.2 Regulatory Agency
Jose Luevano, Project Manager with the DTSC Northern California Schools Unit, Brownfields and Environmental Restoration Program, shall act as representative for regulatory oversight for the project.

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3.3 Removal Contractor
The removal contractor will be responsible for removing the soil identified as containing COCs at concentrations above the CGs from the Project Site, as well as for disposing of the soil off-site in accordance wi th all applicable legal requirements, including providing documentation of the disposal activities. The removal contractor will have an on-site site manager responsible for assuring that the day -to-day work is performed in accordance with the RAW and with any other applicable contractual or legal requirements.

3.4 Environmental Consultant
The environmental consultant will conduct air monitoring to assess whether airbor ne COCs or dust concentrations generated during the removal action exceed worker or community action levels. The consultant has the authority to stop the removal work if such action levels are exceeded. The consultant will also conduct confirmation soil sampling to assess whether the soil containing COCs at concentrations above the CGs have been removed. The consultant will have personnel to fulfill the following roles:
• The Project Manager will be responsible for the technical planning and implementation of the RAW.
• The Field Team Leader and Site Safety Officer for the consultant will be responsible for the day-to-day coordination of the consultant’s field activities to ensure that such activities conform to the specifications presented in the RAW.

3.5 Laboratory
A State-accredited laboratory will be retained to perform analytical testing of confirmation soil samples collected during the removal action. The laboratory manager will report to the environmental consultant’s project manager on all aspects of the sample analysis. The laboratory shall conform to the QA and QC procedures outlined in its Quality Assurance Manual, which can be provided upon request.

Padre proposes to utilize McCampbell Analytical, Inc. (McCampbell) located in Pittsburg, California to provide the required chemical analyses of collected soil and water samples.

McCampbell is certified (No. 1644) by the California State Environmental Accreditation Program Branch to provide the required chemical analyses.

4.0 DATA QUALITY OBJECTIVES
Data quality objectives (DQOs) have been specified for each data collection activity, and the work will be conducted and documented so that the data collected are of sufficient quality for the intended use. DQOs specify the data type, quality, quantity, and uses needed to make decisions, and are the basis for designing data collection activities. The DQOs have been used in designing the data collection activities presented in the RAW. The DQOs for the project are discussed in the following sections.

4.1 Data Quality Objective Process
The project DQOs developed specifically for the planned sampling and analyses program have been determined based on USEPA’s seven- step DQO process (USEPA 2000).

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The QA Manager will evaluate the data collected during the removal action against the project DQOs to determine whether the quantitative and qualitative needs of the sampling and analysis program have been met. The project definition associated with each step of the DQO process can be summarized as follows:

State the Problem: The problem is to remove soil from the Project Site that is impacted with COCs above their respective CGs.

Identify the Decision: The data obtained from the sampling and testing activities will be used to evaluate whether the soil containing COCs above their respective CGs has been removed from the Project Site.

Identify Inputs to the Decision: Inputs to the decision will include results of analytical testing of soil samples from selected locations on the Project Site. The samples will be tested for the specified analytes discussed in Section 2.0 and presented in Table 1 of the QAPP.

Define the Study Boundaries: The boundaries of the field sampling and analysis program will be the perimeter of the excavation area requiring removal of impacted soil.

Develop a Decision Rule: Decisions will be based upon laboratory result for the target constituents presented in Table 1. If no valid concentrations of target compounds are reported above the CGs, then a decision will be made that no further excavation will be required as part of the re sponse action. If valid concentrations of target compounds are reported above the CGs, then further remediation and testing will occur.

Specify Limits on the Decision Error: The results of the analytical testing will be subject to data evaluation following the procedures for data validation specified in this QAPP.

Data will be determined to be if the specified limits on precision, accuracy, representativeness, comparability, completeness, and sensitivity are achieved.

Optimize the Design: The field-sampling program has been designed to provide the type and quantity of data needed to satisfy each of the aforementioned objectives. The RAW provides the specifications for the data collection activities, including the number of samples, respective locations and sampling techniques. The quality of the data will be assessed through the procedures further described in this QAPP.

4.2 Precision, Accuracy, Representativeness, Comparability, and Completeness The basis for assessing the elements of data quality is discussed in the following subsections. In the absence of laboratory -specific precision and accuracy limits, the QC limits listed in this section must be met.

4.2.1 Precision
Precision measures the reproducibility of repetitive measurements. It is strictly defined as the degree of mutual agreement among independent measurements as the result of repeated application of the sample process under similar conditions.

Analytical precision is a measurement of the variability associated with duplicate or replicate analyses of the same sample in the laboratory, and is determined by analysis of laboratory quality control samples such as duplicate control samples (LCSD or DCS), matrix Cupertino Union School District
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spike duplicates (MSD), or sample duplicates. If the recoveries of analytes in the specified control samples are comparable within established control limits, then precision is within limits.

Total precision is a measurement of the variability associated with the entire sampling and analytical process. It is determined by analysis of duplicate or replicate field samples, and measures variability introduced by other than laboratory and field operations. Field duplicate samples are analyzed to assess field and analytical precision.

Duplicate results are assessed using the relative percent difference (RPD) between duplicate measurements. If the RPD for laboratory quality control samples exceeds 30 percent, data shall be qualified as described in the applicable validation procedure. If the RPD between primary and duplicate field samples exceeds 100 percent for soil, data shall be qualified as described in the applicable validation procedure. The RPD shall be calculated as follows:
% RPD = 100% x Abs(X2 - X 1)
Avg(X2 + X 1)

W here X2 is the larger of the two observed values, and X1 is the smaller of the two observed values.

4.2.2 Accuracy
Accuracy is a statistical measurement of correctness and includes components of random error (variability due to imprecision) and systematic error. It reflects the total error associated with a measurement. A measurement is accurate when the value reported does not differ from the true value or known concentration of the spike or standard. Accuracy of laboratory analyses shall be assessed by laboratory control samples, surrogate standards, matrix spikes, and initial and continuing calibrations of instruments. Laboratory accuracy is expressed as the percent recovery (%R). If the percent recovery is determined to be outside of acceptance criteria, data shall be qualified as described in the applicable validation procedure.

The calculation of percent recovery is provided below:
% R = 100 x Xs – X
T
Where Xs is the measured value of the spiked sample, X is the measured value of the unspiked sample, and T is the true value of the spike solution added. Field accuracy shall be assessed through the analysis of field equipment blanks. Analysis of blanks shall monitor errors associated with the sampling process and field contamination. The DQO for field equipment blanks is that all values are less than the reporting limit for each target constituent. If contamination is reported in a field equipment blank, the associated data shall be qualified as described in the applicable validation procedure.

4.2.3 Representativeness
Representativeness is the degree to which data accurately and precisely represent selected characteristics of the media sampled. Representativeness of data collection is addressed by careful preparation of sampling and analysis programs. This QAPP, together with the RAW, addresses representativeness by specifying sufficient and proper numbers and locations of samples; incorporating appropriate sampling methodologies; specifying proper Cupertino Union School District
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sample collection techniques and decontamination procedures; selecting appropriate laboratory methods to prepare and analyze soil samples; and establishing proper field and laboratory QA/QC procedures.

5.0 QUALITY CONTROL ELEMENTS
This section presents QC requirements relevant to analysis of environmental samples that shall be followed during all project analytical activities. The purpose of the QC program is to produce data of known quality that satisfy the project objectives and that meet or exceed the requirements of the standard methods of analysis. This program provides a mechanism for ongoing control and evaluation of data quality measurements through the use of QC materials.

5.1 Quality Control Procedures
The chemical data to be collected for this purpose shall be used to determine that the extent of contamination is properly evaluated. As such, it is critical that the chemical data be of the highest confidence and quality. Consequently, strict QA/QC procedures shall be adhered to.

These procedures include:
• Adherence to strict protocols for field sampling and decontamination procedures; • Collection and laboratory analysis of appropriate field equipment blanks to monitor for contamination of samples in the field; and
• Collection of field duplicates and laboratory analysis of matrix spike, matrix spike duplicate, and field duplicate samples to evaluate precision and accuracy.

5.1.1 Equipment Decontamination
Non-dedicated equipment shall be decontaminated before and after each sample is collected. The equipment shall be washed in a non- phosphate detergent and deionized/distilled water, rinsed in deionized/distilled, and then double rinsed.

5.1.2 Standards
Standards will be used to calibrate or to prepare samples for analyses by laboratory and field equipment ( e.g., XRF instrument). Standards shall be certified by the National Institute of Standards and Technology (NIST), USEPA, or other equivalent sources. The standards shall be current. The expiration date shall be established by the manufacturer, or based on chemical stability, the possibility of contamination, and environmental and storage conditions. Standards shall be labeled with expiration dates, and shall reference primary standard sources if applicable. Expired standards shall be discarded.

5.1.3 Supplies
All supplies shall be inspected prior to their use in the field or laboratory. The descriptions for sample collection and analysis contained in the methods shall be used as a guideline for establishing the acceptance criteria for supplies. A current inventory and appropriate storage system for these materials shall assure their integrity prior to use. Efficiency and purity of supplies shall be monitored through the use of standards and blank samples.

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5.1.4 Holding Time Compliance
Sample preparation and analysis shall be completed within the required method holding times. Holding time begins at the time of sample collection. If holding times are exceeded, and the analyses are performed, the associated results shall be qualified as described in the applicable validation procedure. The following definitions of extraction and analysis compliance are used to assess holding times:
• Preparation or Extraction Completion – Completion of the sample preparation process as described in the applicable method, prior to any necessary extract cleanup.
• Analysis Completion – Completion of all analytical runs, including dilutions, second column confirmations, and any required re-analyses.

5.1.5 Preventive Maintenance
The field team leader is responsible for documenting the maintenance of all field equipment prescribed in the manufacturer’s specifications. Scheduled maintenance shall be performed by trained personnel. The analytical laboratory is responsible for all analytical equipment calibration and maintenance as described in their laboratory QA Manual.

Subcontractors are responsible for maintenance of all equipment needed to carry out subcontracted duties.

5.2 Quality Assurance and Quality Control (QA/QC) Samples The purpose of this QA/QC program is to produce data of known quality that satisfy the project objectives and that meet or exceed the requirements of the standard methods of analysis. This program provides a mechanism for ongoing control and evaluation of data quality measurements through the use of QC materials. Quality assurance and quality control samples shall be collected as part of the overall QA/QC program.

5.2.1 Duplicate Sample Collection
Duplicate field sampling is a sample collected using the same methodology as primary field sample collection. Duplicate samples are used to assist in the measurement of precision (discussed in Section 4.2.1, above), or reproducibility, of the field sampling technique. Together with analytical precision, the use of field duplicate sample collection and analys es, assists in measuring the total variability associated with the entire sampling and analytical process. Field duplicate samples shall be collected at a rate of one duplicate per ten (10) primary samples collected.

5.2.2 Laboratory Reagent Blanks
A laboratory reagent blank is de -ionized or distilled water that is extracted by the laboratory and analyzed as a sample. Analysis of the reagent blank indicates potential sources of contamination from laboratory procedures (e.g., contaminated reagents, improperly cleaned laboratory equipment, or persistent contamination due to presence of certain compounds in the ambient laboratory air). A reagent blank shall be analyzed at least once a day f or each method utilized by the laboratory for that day.

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5.2.3 Field Equipment Blanks
A field equipment blank is a sample that is prepared in the field by pouring de- ionized or distilled water into cleaned sampling equipment. The water is then collected and analyzed as a sample. The field equipment blank gives an indication of contamination from field procedures (e.g., improperly cleaned sampling equipment, cross -contamination). Field equipment blanks shall be collected at a minimum frequency of at least one per day. The field equipment blanks should be analyzed using the same analyses requested for the associated primary samples collected.

5.2.4 Matrix Spike Samples
Matrix spikes are performed by the analytical laboratory to evaluate the efficiency of the sample extraction and analysis procedures, and are necessary because matrix interference (i.e., interference from the soil matrix) may have a widely varying impact on the accuracy and precision of the extraction analysis. The matrix spike is prepared by the addition of known quantities or target compounds to a sample. The sample is extracted and analyzed. The results of the analysis are compared with the known additions and a matrix spike recovery is calculated giving an evaluation of the accuracy of the extr action and analysis procedures. Matrix spike recoveries are reviewed to check that they are within acceptable range. However, the acceptable ranges vary widely with both sample matrix and analytical method. Matrix spikes and matrix spike duplicates shall be analyzed by the laboratory at a frequency of at least one per 20, or 5 percent of the primary field samples. Typically, matrix spikes are performed in duplicate in order to evaluate the precision of the procedures as well as the accuracy. Precision objectives (represented by agreement between matrix spike and matrix spike duplicate recoveries) and accuracy objectives (represented by matrix spike recovery results) are based on statistically generated limits established annually by the analytical laboratory . It is important to note that these objectives are to be viewed as goals, not as criteria. If matrix bias is suspected, the associated data shall be qualified and the direction of the bias indicated in the data validation report.

6.0 SAMPLING PROCEDURES
The defensibility of data depends on the use of well defined, accepted sampling procedures. This section describes the sampling and handling procedures that shall be followed for each sampling event.

6.1 Field Procedures
Field procedures have been developed to ensure the integrity of the quality of chemical data generated. These procedures are outlined in the RAW.

6.2 Sample Containers, Preservation and Holding Times
Soil samples will be collected into 2- inch by 6 -inch stainless steel sample tubes . Once collected, each containerized sample will be capped, labeled, and placed in a sample cooler with ice for subsequent transport to the offsite analytical laboratory. Samples will be analyzed within the maximum holding times for the relevant laboratory analysis (Table 1).

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6.3 Sample Handling and Storing
In the field, each sample container shall be marked with the sampling location number, and date and time of sample collection. All sample containers shall be wiped with paper towels and securely packed, in a cooler on ice, in preparation for delivery to the laboratory. Upon receipt of the samples, the laboratory shall immediately notify the Project Manager if conditions or problems are identified which require immediate resolution. Such conditions include container breakage, missing or improper chain-of-custody, exceeded holding times, missing or illegible sample labeling, or temperature excursions.

6.4 Sample Custody
For each sample that is submitted to the laboratory for analysis, an entry shall be made on a chain-of-custody form supplied by the laboratory. The information to be recorded includes the sampling date and time, sample identification number, matrix type, requested analyses and methods, preservatives, and the sampler’s name. Sampling team members shall maintain custody of the samples until they are relinquished to laboratory personnel or a professional courier service. The chain- of-custody form shall accompany the samples from the time of collection until received by the laboratory. Each party in possession of the samples shall sign the chain- of-custody form signifying receipt. The chain- of-custody form shall be placed in a plastic bag and shipped with samples inside the cooler. A copy of the original completed form shall be provided by the laboratory along with the report of results. Upon receipt, the laboratory shall inspect the condition of the sample containers and report the information on the chain- of- custody or similar form.

7.0 ANALYTICAL PROCEDURES
The analytical methods used for this project are pr imarily USEPA-approved methods.

Specific analytical methods procedures are detailed in the laboratory QA Manual and standard operating procedures of the selected laboratory. Table 1 summarizes the analytical methods, reporting limits and holding times for the lead analyses for the site.

7.1 Internal Standards
Internal standards are measured amounts of method- specified compounds added after preparation, or extraction, of a sample. Internal standards are added to samples, controls, and blanks in accordance with method requirements to identify column injection losses, purging losses, or viscosity effects. Acceptance limits for internal standard recoveries are set forth in the applicable method. If the internal standard recovery falls outside of acceptance criteria, the instrument shall be checked for malfunction and the sample shall be reanalyzed after any problems are resolved.

7.2 Method Detection Limits
The method detection limit (MDL) is the minimum concentration of an analyte, or compound that can be measur ed and reported with 99 percent confidence that the concentration is greater than zero. MDLs are established for each method, matrix and analyte, and for each instrument used to analyze project samples. MDLs are derived using the procedures described in 40CFR 136, Appendix B (CFR, 2008). USEPA requires that MDLs be Cupertino Union School District
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established on an annual basis. MDLs must be less than applicable report limits for each target analyte.

7.3 Laboratory Instrument Calibration
Analytical instruments shall be calibrated in accordance with the procedures specified in the applicable method. All analytes that are reported shall be present in the initial and continuing calibrations, and these calibrations must meet the acceptance criteria specified in the reference methods. Records of standard preparation and instrument calibration shall be maintained.

Records shall unambiguously trace the preparation of standards and their use in calibration and quantitation of sample results. Calibration records shall be traceable to standard materials as described in Section 5.1.2. At the onset of analysis, instrument calibrations shall be checked using all of the analytes of interest. At a minimum, calibration criteria shall satisfy method requirements. Analyte concentrations can be determined with either calibration curves or response factors, as defined in the method. Guidance provided in SW -846 (USEPA, 1996; 2007) should be considered to determine appropriate evaluation procedures.

7.4 Field Instrument Calibration
Proper maintenance, calibration, and operation of each field instrument will be the responsibility of field personnel assigned to the particular field activity. All instruments and equipment used during the field program will be maintained, calibrated, and operated according to the manufacturer’s guidelines and recommendations.

Calibration procedures for field equipment are summarized below. • A schedule and record of instrument calibration will be maintained throughout the duration of the study.
• All field equipment requiring regular calibration will be calibrated at least once per day;
• Relevant manuals will be kept with field personnel during the p erformance of field activities;
• All equipment will receive routine maintenance checks to minimize equipment breakdown in the field or laboratory; and
• Any items found to be inoperable will be taken out of use and a note stating the time and date of this action will be made in the field log.

8.0 DATA REPORTING
This section presents reporting requirements relevant to the data produced during all project analytical activities.

8.1 Field Data
Data measured by field instruments shall be recorded in field notebooks, laptops, and/or on required field forms. Units of measure for field analyses are identified on the field forms. The field data shall be reviewed by the Project Manager to evaluate completeness of the field records and appropriateness of the field methods employed. All field records shall be retained in the project files.

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8.2 Laboratory Data
Analytical data shall contain the necessary sample results and quality control data to evaluate the DQOs defined for the project. The laboratory reports shall include the following data and summary forms:
• narrative, cross-reference, chain-of-custody, and method references; • analytical results;
• blank results;
• laboratory control sample recoveries;
• duplicate sample results or duplicate spike recoveries; and • sample spike recoveries.

Data validation criteria are derived from the USEPA Contract Laboratory Program National Functional Guidelines for Inorganic Data Rev iew (USEPA, 2004). The National Functional Guidelines provide specific data validation criteria that can be applied to data generated for this investigation.

The laboratory data shall be reviewed for compliance with the applicable method and the quality of the data reported. The following summarizes the areas of data validation. • data completeness;
• holding times;
• calibrations;
• blanks;
• laboratory control samples;
• matrix spike/matrix spike duplicates;
• surrogates/internal standards (as applicable);
• field QC samples; and
• compound identification and quantification.

The application of data validation criteria is a function of project -specific DQOs. The laboratory’s QA/QC Manager and the consultants Project Manager shall determine if the data quality objectives for the analytical data have been met.

8.3 Procedures for Data Validation
An independent data validation will be completed, independent of the laboratory providing analytical services. Guidance for performing data validation for the types of analyses to be ut ilized for this investigation is provided in the National Functional Guidelines. Data validation shall be documented in a manner consistent with these functional guidelines. The results of the data validation shall be recorded on validation forms and reported in the removal action completion report.

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8.4 Data Qualifiers
The data validation procedures were designed to review each data set and identify biases inherent to the data and determine its usefulness. Data validation flags are applied to those sample results that fall outside of specified tolerance limits, and, therefore, do not meet the program’s quality assurance objectives as described in Section 4.2. Data validation flags to be used for this project are defined in the National Functional Guidelines. Data validation flags shall indicate if results are considered anomalous, estimated, or rejected. Only rejected data are considered unusable for decision-making purposes; however, other qualified data may require further verification.

9.0 PERFORMANCE AND SYSTEMS AUDITS
This section describes responsibilities; and requirements and methods for assessing the effectiveness of the project implementation and associated QA and QC activities.

9.1 Field Performance
Field performance will be monitored through review of sample collection documentation, sample handling records (COC forms), field notebooks, and field measurements by the consultant/contractor will report any significant field performance issues and any corrective actions in the Removal Action Completion Report.

9.2 Laboratory Audits
Any selected mobile or offsite laboratory shall be licensed by the State of California as a certified testing laboratory for hazardous waste and soil analyses. Due to the small scope of the project, an independent laboratory audit is not proposed.

9.3 Reports to Management and Responsibilities
It is the responsibility of the Project Manager to determine if any deviations in protocols described in the QAPP will result in any adverse effect on the project conclusions. I f it is determined that corrective action is necessary, procedures outline in Section G.9.4 shall be followed.

9.4 Correction Action
Corrective actions shall be initiated if data quality indicators suggest that DQOs have not been met. Corrective actions shall begin with identifying the source of the problem. Potential problem sources include failure to adhere to method procedures, improper data reduction, equipment malfunctions, or systemic contamination. The first level of responsibility for identifying the problems and initiating corrective action lies with the analyst/field personnel. The second level of responsibility lies with any person reviewing the data. Corrective actions may include more intensive staff training, equipment repair followed by a more intensive preventive maintenance program, or removal of the source of systemic contamination. Once resolved, the corrective action procedure shall be fully documented, and if DQOs were not met, the samples in question may be recollected and/or reanalyzed utilizing a properly functioning system.

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10.0 REFERENCES
California Department of Toxic Substances Control, Interim Guidance, Evaluation of School Sites with Potential Contamination as a Result of Lead from Lead- Based-Paint, Organochlorine Pesticides from Temiticides, and Polychlorinated Biphenyls from Electrical Transformers, revised June 9, 2006.

California Department of Toxic Substances Control, Preliminary Endangerment Assessment Guidance Manual (January 1994, Interim Final – Final October 2015).

Code of Federal Regulations (CFR). 2008. Definition and Procedure for the Determination of the Method Detection Limit—Revision 1.11. Title 40, Part 136, Appendix B. March 24.

United States Environmental Protection Agency (USEPA). 1996. Test Methods for Evaluating Solid Waste, Physical/Chemical Methods (SW-846). Office of Solid Waste. 3rd Edition, Update III. December.

United States Environmental Protection Agency (USEPA). 2001. EPA Requirements for Quality Assurance Project Plans (EPA QA/R -5), EPA/240/B -01/003. March (Reissued May 2006).

USEPA. 2002. Guidance for Quality Assurance Project Plans (EPA QA/G -5), EPA/240/R- 02/009. December.

USEPA. 2004. USEPA Contract Laboratory Program National Functional Guidelines for Inorganic Data Review, EPA 540-R- 04-004. Office of Superfund Remediation and Technology Innovation (OSRTI). October.

USEPA. 2006. Guidance on Systematic Planning Using the Data Quality Objectives Process (EPA QA/G-4), EPA/240/B-06/001. February.

USEPA. 2007. Test Methods for Evaluating Solid Waste, Physical/Chemical Methods (SW-846).

Office of Solid Waste. 3rd Edition, Update IV. February.

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Table 1: Reporting Limits and Holding Times for COCs
Analytical Method Reporting Limit Reporting
Limit Units
Holding
Times
OCPs by EPA 8081A Chlordane - 0.025 mg/kg 14 days
TTLC Chlordane – 2.5 mg/kg 14 days
STLC Chlordane - 0.25 mg/L 14 days
TCLP Chlordane - 0.03 mg/L 14 days
Lead by EPA 6010 0.5 mg/kg 180 days
TTLC 1,000 mg/kg 180 days
STLC 5.0 mg/L 180 days
TCLP 5.0 mg/L 180 days
Notes:

TTLC – total threshold limit concentration
STLC – soluble threshold limit concentration analyzed by WET or TCLP WET – California waste extraction test
TCLP – toxicity characteristic leaching procedure
NA – not applicable

APPENDIX I

TRANSPORTATION PLAN

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APPENDIX I

TRANSPORTATION PLAN FOR OFF-SITE DISPOSAL
Cupertino Union School District
Sedgwick Elementary School Expansion Project
Cupertino, Santa Clara County, California

INTRODUCTION
The Cupertino Union School District purchased the Project Site in 2017 and is located at 10480 Finch Avenue in Cupertino, California (Project Site). At this time, no specific plans have been developed for improving the property. However, based on chemicals of concern (COCs) identified in surficial soil at the Project Site above regulatory screening levels, the District is implementing soil cleanup activities under the oversight of California Department of Toxic Substances Control (DTSC). The COCs are identified to be chlordane, a pesticide, and lead from weathering of lead- based paint from building structures.

Padre completed a Preliminary Environmental Assessment (PEA) for the Project Site dated September 2015 and a Supplemental Site Investigation (SSI) dated January 2016. The PEA and SSI i dentified organochlorine pesticides (OCPs) and lead as chemicals of concern (COCs) in soil requiring a response action. The selected response action for the COCs is excavation and off -site disposal at a licensed landfill facility.

Based on established remedial cleanup goals (CGs), approximately 300 cubic yards of impacted soil will be excavated, chemically characterized, transported, and disposed of at an appropriate disposal facility.

A Removal Action Workplan (RAW) has been prepared to address the excavation and offsite disposal of surface soil at the Project Site containing COCs. This Transportation Plan has been prepared as a key component of the RAW. All removal, transportation and disposal activities will be performed in accordance with all applicable federal, state, and local laws, regulations, and ordinances.

WASTE CHARACTERIZATION AND QUANTITY
The COCs identified to be remediated include OPCs and lead in near surface soils. The planned volume of excavated soil is approximately 300 cubic yards of soil

(insitu). Soil is typically transported and disposed of by weight. The estimated quantity of soil to be transported and disposed of has been calculated to be approximately 486 tons, which at 22 tons per load, would result in approximately 22 truck and trailer loads.

WASTE CHARACTERIZATION
The excavated soil will be temporarily stored as approximately 2 stockpiles. The soil stockpile s will be characterized to determine its waste classification per the requirements of the disposal facility. One four -point composite soil sample wi ll be collected from each stockpile and submitted to the analytical laboratory to be chemically analyzed for OCPs and CAM 17 metals . It is anticipated that soils excavated from the Cupertino Union School District
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Project Site will be managed (handled, transported and disposed of) as a non-hazardous waste.

Waste characterization and landfill approval will be obtained prior to transporting soil off the Project Site. If detected concentrations of COCs do not exceed the California total threshold limit concentration (TTLC), then the soil will be disposed of as a non- hazardous waste. If detected concentrations of COCs exceed the TTLC, then the soil will be classified as a hazardous waste. The soil sample is then analyzed for the soluble threshold limit concentration (STLC) by the California Waste Extraction Test (WET) or the toxicity characteristic leaching procedure (TCLP), depending on the acceptance criteria of the landfill facility. If detected concentrations of COCs exceed the STLC/TCLP then the soil will be classified as a RCRA -hazardous waste. The values for waste characterization are listed below:

Compound TTLC STLC TCLP
Chlordane 2.5 mg/kg 0.25 mg/L 0.03 mg/L
Lead 1,000 mg/kg 5.0 mg/L 5.0 mg/L
The District will then be required to obtain a California EPA temporary identification number for the disposal of the waste. Persons who generate, transport or offer for transport, treat, store, or dispose of hazardous waste generally must have an identification (ID) number, which is used to identify the hazardous waste handler and to track the waste from its point of origin to its final disposal (referred to as “cradle to grave”). Instructions on how to obtain a temporary ID number can be found at the DTSC website: www.dtsc.ca.gov/IDManifest/index.cfm#identification(ID)Numbers .

Compliance with the DTSC requirements of hazardous waste generation, temporary onsite storage, transportation and disposal is required. Any container used for onsite storage will be properly labeled with a hazardous waste label. Within 90 days after its generation, the hazardous waste will be transported offsite for disposal. Any shipment of hazardous wastes in California will be transported by a registered hazardous waste hauler under a uniform hazardous waste manifest. Land ban requirements will also be followed as necessary.

REQUIREMENTS OF TRANPORTERS
The removal contractor will be responsible for subcontracting with a qualified and licensed waste transporter. T he selected waste transporter will be a California Registered Hazardous Waste Hauler, and will be fully licensed and insured to transport non-hazardous and/or hazardous soil (if necessary). The transporter will provide the environmental consultant with a current copy of their California Registered Hazardous Waste Transporter certification and proof of insurance. While onsite every driver will present a current driver’s license and proof of insurance (if requested) to the Project Manager and/or the DTSC representative.

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TRAFFIC CONTROL PROCEDURES
Trucks will enter and exit the Project Site from the northwest corner located at the intersection of Finch Avenue and Phil Lane (refer to Plate H -1). It appears that two to three trucks can be staged onsite, while waiting to be loaded. Additional trucks may be staged off -site at a location to be determined by the contractor. Trucks will be directed to the loading area. While onsite, all vehicles will be required to maintain slow speeds (i.e., less than 5 mph) for safety purposes and for dust control measures. After loading, the trucks will proceed to the “Decon Area” for final inspection and authorization of waste manifests.

WORKSHOP

SINGLE-ROOM

DWELLING

OVERHANG

OVERHANG

RESIDENCE

PHIL LANE

SOIL STOCKPILE

AREA TRUCK LOADING
AREA

INGRESS
EGRESS

TRUCK INSPECTION
AREA
DECON
(WORKERS)
DECON
(EQUIPMENT)

SUPPORT ZONEPROJECT SITE BOUNDARY

EXCLUSION ZONE BOUNDARY

ESTIMATED EXTENT OF
COCs

TRUCK ROUTE
associates, inc.

ENGINEERS, GEOLOGISTS &

ENVIRONMENTAL SCIENTISTS
PLATE I-1
DR. BY
AC
APP. BYWORK ZONES
DATE
PROJECT NO.
3/12/18AJK 1601-3361
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TRUCK LOADING PROCEDURES
The following loading procedures will be followed by the removal contactor:
• The soil will be loaded into trucks in the exclusion zone; • The loader operator will take care not to spill soil outside the trucks container compartment(s);
• W ater will be applied for dust control purposes during loading operations as needed;
• All loads will be covered;
• The trucks will be inspected and decontaminated by brushing and scraping to remove soil and dust. If dry methods are not effective, wet methods may be used such as pressure washing;
• Generated soil from decontamination activities will be collected using hand tools and or mechanical equipment and returned to the stockpile staging area;
• Each truck shipment will be checked for the proper shipping documents (waste manifests, licenses, insurance and transportation plan); and • Each truck shipment will be recorded in the field logbook.

SHIPMENT DOCUMENTATION
Non-Hazardous Waste. For any excavated soil that is profiled as non -hazardous waste, a proper shipping document (such as bill of lading, weigh ticket, invoice) of the hauler will be used to document and accompany each truck shipment. The removal contractor will maintain a copy of the shipping document for each truckload onsite until completion of the removal action.

Hazardous Waste Shipment . For any excavated soil that is profiled as a hazardous waste, the Uniform Hazardous Waste Manifest form will be used to document the movement of hazardous waste soils from the point of generation to the point of ultimate disposition. Prior to transporting the excavated soil off -site, an authorized representative of the District or its designated representative will sign each hazardous waste manifest. The hazardous waste hauler will sign the manifest and distribute one signed copy to the removal action contractor’s site manager. The removal action contractor’s site manager will maintain a copy of the hazardous waste manifest for each truckload on-site until completion of the removal action.

DISPOSAL FACILITIES
Based on the PEA soil analytical results and proposed excavation activities, the excavated soil is anticipated to be disposed of as a non-hazardous waste. The following waste facilit y has been identified to accept and store and/or treat non-hazardous soil generated from the removal activities:

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Non-Hazardous Waste Landfill (Class II)
New Island Sanitary Landfill
1601 Dixon Landing Road
Milpitas, California 95035
(408) 262-2871
In the event that waste characterization identifies that the soil is required to be disposed of as a non- RCRA hazardous waste, the following waste f acilities have been identified to accept and store and/or treat non -RCRA hazardous soil generated from the removal activities:

Hazardous Waste Landfill (Class I)
Clean Harbors, LLC
Buttonwillow (Hazardous Waste Facility)
2500 West Lokern Road
McKittrick, California 93251
(661) 762-6200

TRANSPORTATION ROUTE (CLASS II LANDFILL)
A highway route has been identified for transportation of soil from the Project Site to the Newby Island Sanitary La ndfill Facility loc ated in Suisun City , California. The selected route is the most direct and will provide the least risk of exposure to surrounding communities. None of the roadways selected are listed with the California Highway Patrol as prohibited for hauling non-hazardous waste. The transportation route to the landfill is described below and illustrated on the associated map.

Route to Newby Island Sanitary Landfill, 1601 Dixon Landing Road, Milpitas, California (non- hazardous, Class II, waste facility):

1. Loaded trucks will exit from the Project Site’s northeast gate and turn left on Phil Lane;

2. Head west of Phil Lane (0.2 mi);

3. Turn right onto Miller Avenue (0.5 mi);

4. Continue onto North Wolfe Road (0.6 mi)

5. Use right lane to take Interstate 280 N onramp (0.4 mi);

6. Merge onto I-280 N (1.8 mi);

7. Use the right two lanes to take Exit 12A to merge onto CA- 85 N toward Mountain View (3.8 mi);

8. Take exit 22C to merge onto CA- 237 E toward Oakland/San Jose/US -101S (8.6 mi);

9. Use the middle 2 lanes to take exit toward I-880 N (0.2 mi); Cupertino Union School District
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10. Use the right 2 lanes to keep left at the fork and follow signs for I -880 N/Oakland (200 ft.);

11. Keep right at the fork and merge onto I-880 N (1.8 mi);

12. Use the 2 nd from the right lane to take exit 10 for Dixon Landing Road (0.2 mi.);

13. Keep left at the fork, follow signs for Dixon Landing Road W (0.3 mi);

14. Keep right at the fork, follow signs for Dixon Landing Road W (0.2 mi);

15. Use the right 2 land to turn right onto Dixon Landing Road (0.5 mi); and

16. Arrive 1601 Dixon Landing Road, Milpitas, CA 94585. (Facility is on the left) Total trip approximately 19 miles; 30 min.

Route to Newby Island Sanitary Landfill, 1601 Dixon Landing Rd. Milpitas, CA.

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TRANSPORTATION ROUTE (CLASS I LANDFILL)
A highway route has been identified for transportation of soil from the Project Site to the Clean Harbors Buttonwillow Hazardous Waste Facility located in McKittrick, California. The selected route is the most direct and will provide the least risk of exposure to surrounding communities. None of the roadways selected are listed with the California Highway Patrol as prohibited for hauling non-hazardous waste or hazardous waste. The transportation route to the landfill is described below and illustrated on the associated map.

Route to Clean Harbors Buttonwillow Facility, 2500 West Lokern Road, McKittrick, California (Class I hazardous waste facility):

1. Loaded trucks will exit from the Project Site’s northeast gate and turn left on Phil Lane;

2. Head west of Phil Lane (0.2 mi);

3. Turn right onto Miller Avenue (0.5 mi);

4. Continue onto North Wolfe Road (0.4 mi.);

5. Use right lane to take Interstate I-280 S onramp (0.2 mi);

6. Merge onto I-280 N (9.2 mi);

7. Use the right 2 lanes to merge onto US-101 S toward Los Angeles (29.1 mi);

8. Use the 2nd from the right lane to take exit 356 for 10th Street/CA-152 E (0.3 mi);

9. Use the left 2 lanes to turn sharply left onto CA-152 E/E 10th Street/E Pacheco Pass Road (40.7 mi);

10. Use the right lane to merge onto I-5 S via the ramp to Los Angeles (0.5 mi);

11. Merge onto I-5 S (124 mi);

12. Take exit 278 for CA-46 toward Lost Hills/Wasco (0.3 mi);

13. Turn right onto CA-46 W (1.9 mi);

14. Turn left onto Woodward Street (0.3 mi);

15. Continue onto Lost Hills Road (12.1 mi);

16. Turn left onto CA-33 S (3.1 mi);

17. Turn left on Lokern Road; and

18. Arrive at Clean Harbors Buttonwillow, 2500 W Lokern Rd., McKittrick, CA. (On the left)
Total trip approximately 226 miles; 3 hrs, 31 min.

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Route Map to U.S. Ecology Nevada Inc.

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CONTINGENCY PLAN
The waste hauler is required to have a contingency plan prepared for emergency situations (vehicle breakdown, accident, waste spill, waste leak, fire, explosion, etc.) during transportation of excavated soils from the Project Site to the disposal facility. The selected transport contractor will provide to the Project Site Manager the name, contact and phone numbers of their Emergency Response Contractor (ERC).

In the event of a spill, accident, or breakdown, the transport driver will stay with the truck until law enforcement, California Highway Patrol, or other official assistance arrives. The driver will contact their dispatcher who will in turn contact the ERC. The ERC is responsible for contacting all the appropriate outside agencies based on the knowledge of existing conditions (e.g., law enforcement, Caltrans, RWQCB, State or County Health Departments, California Office of Emergency Services, etc.).

APPENDIX J

DTSC ADVISORY ON IMPORTED FILL MATERIAL