PR-2023-001469 General Plan Amendment, Spe cific Plan Amendment, Rezone, Site Pl an Review, Tentative Tract Map 38624,
Certificate of Appropriateness
Iron Lofts
Appendix E-1
Response Plan, Former Riverside Scrap and Iron Metal Property, 2993 6th Street, Riverside, CA 92507
GSI Environmental
November 4, 2024
RESPONSE PLAN
FORMER RIVERSIDE SCRAP IRON & METAL PROPERTY
2993 6th Street
Riverside, California 92507
Department of Toxic Substances Control Docket No HAS-FY21/22-032
Issued: November 4, 2024
Prepared for: IRON LOFTS LLC
1201 Dove Street, Suite 520
Newport Beach, California 92660
Prepared by: GSI ENVIRONMENTAL INC.
19200 Von Karman Avenue, Suite 800
Irvine, California 92612
949.679.1070
www.gsienv.com
GSI Project No. 6239
RESPONSE PLAN
FORMER RIVERSIDE SCRAP IRON & METAL PROPERTY
2993 6th Street
Riverside, California 92507
Department of Toxic Substances Control Docket No HAS-FY21/22-032
This Response Plan was prepared by the staff of GSI Environmental Inc., under the supervision of the Engineer(s) and/or Geologist(s) whose signatures appear hereon.
The findings, recommendations, specifications, or professional opinions were prepared in accordance with generally accepted professional engineering and/or geologic practice . No warranty is expressed or implied.
Issued: November 4, 2024
Timothy F. Wood, PG, CHG
Vice President & Principal Geologist
Samantha Curtis, PG
Senior Geologist
GSI Job No.: 6239
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RESPONSE PLAN
Former Riverside Scrap Iron & Metal Property
2993 6th Street
Riverside, California 92507
TABLE OF CONTENTS
Former Riverside Scrap Iron & Metal Property i Response Plan
1.0 INTRODUCTION ................................................................................................................. 1
1.1 Objectives of the Response Plan .................................................................................. 1
1.2 Current Regulatory Status ............................................................................................. 1
2.0 SITE DESCRIPTION ............................................................................................................ 3
2.1 Current and Historical Uses .......................................................................................... 3
2.2 Site Geology and Hydrogeology .................................................................................... 4
2.3 Site Vicinity ................................................................................................................... 4
2.4 Site Development Plan .................................................................................................. 4
3.0 SITE CHARACTERIZATION ............................................................................................... 5
3.1 Site Investigation ........................................................................................................... 5
3.1.1 2011 Phase II Investigation .................................................................................. 6
3.1.2 2015 Additional Phase II Investigation ................................................................. 6
3.1.3 2017 Off-Site Preliminary Environmental Assessment ......................................... 7
3.1.4 2018 Additional On-Site PCB Sampling and Analysis .......................................... 8
3.1.5 2020 Revised Remedial Action Plan .................................................................... 9
3.1.6 2021 Phase I ESA .............................................................................................. 10
3.2 2022 Site Assessment Plan and Report of Findings .................................................... 11
3.3 2023 Soil Vapor Investigation Reports ........................................................................ 11
4.0 NATURE AND EXTENT OF CONTAMINATION ............................................................... 14
4.1 Soil .............................................................................................................................. 14
4.2 Soil Vapor ................................................................................................................... 15
5.0 CONCEPTUAL SITE MODEL ........................................................................................... 16
6.0 REMEDIAL ACTION OBJECTIVES .................................................................................. 18
6.1 Remedial Action Objective for Soil .............................................................................. 18
6.2 Applicable or Relevant and Appropriate Requirements and To Be Considered Criteria ..................................................................................................... 18
6.2.1 Overview of ARARs ........................................................................................... 19
6.2.2 Overview of TBC Criteria ................................................................................... 19
6.3 Remedial Goals........................................................................................................... 19
6.4 Areas Exceeding Remedial Goals ............................................................................... 20
7.0 SUMMARY OF FEASIBILITY STUDY ............................................................................... 21
7.1 Remedial Action Alternatives – Soil ............................................................................. 24
7.1.1 Alternative 1 ‐ No Further Action ........................................................................ 25
7.1.2 Alternative 2 ‐ Containment through Surface Capping ....................................... 25
7.1.3 Alternative 3 ‐ Excavation and Off-Site Disposal ................................................ 25 GSI Job No.: 6239
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7.2 Remedial Action Alternatives – Soil Vapor .................................................................. 27
7.2.1 Alternative A ‐ Vapor Intrusion Mitigation Measures at All on-Site Buildings ............................................................................................................ 27
7.2.2 Alternative B ‐ Excavation of Soil with VOCs in Soil Vapor and Off-Site Disposal ............................................................................................................. 27
7.2.3 Alternative C ‐ Soil Vapor Extraction (SVE) ........................................................ 28
7.2.4 Alternative D ‐ Vapor Intrusion Mitigation Measures at All on-Site Buildings with Institutional Controls .................................................................... 28
7.3 Recommended Remedial Alternatives ........................................................................ 28
8.0 REMEDIAL ACTION IMPLEMENTATION ......................................................................... 29
8.1 Excavation Plan .......................................................................................................... 29
8.1.1 Soil Impacted with PCBs exceeding 50 mg/kg ................................................... 29
8.1.2 Soil Impacted with RCRA Levels of Lead ........................................................... 30
8.1.3 Lead, PCB, Arsenic and PAH exceeding Residential Soil RBSLs ...................... 30
8.1.4 Residential Property Excavations ....................................................................... 30
8.1.5 Indoor Air ........................................................................................................... 30
8.2 Permitting .................................................................................................................... 31
8.2.1 SCAQMD Rules 401, 403, and 1466.................................................................. 31
8.2.2 Surface Runoff Control....................................................................................... 31
8.2.3 Waste Transportation and Disposal Documentation, and Transporter Requirements .................................................................................................... 32
8.3 Site Preparation and Utility Clearance ......................................................................... 32
8.4 Field Variances ........................................................................................................... 32
8.5 Waste Profiling and Classification ............................................................................... 32
8.6 Investigation Derived Waste ........................................................................................ 33
8.7 Health and Safety ........................................................................................................ 33
9.0 CONFIRMATION SAMPLING............................................................................................ 33
9.1 Soil Sampling .............................................................................................................. 33
9.2 Indoor Air Sampling ..................................................................................................... 34
9.3 Human Health Risk Assessment ................................................................................. 35
10.0 PUBLIC PARTICIPATION AND CEQA DOCUMENTATION ............................................. 35
11.0 PROJECT SCHEDULE ..................................................................................................... 36
12.0 REFERENCES .................................................................................................................. 37
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Former Riverside Scrap Iron & Metal Property iii Response Plan
EXHIBITS
Exhibit 1-1. Requirements of Health and Safety Code (HSC) Section 25395.96(a) and (b) ............................................................................................................................ 2 Exhibit 3-1. Temporal Trends for PCE – November vs. May ....................................................13 Exhibit 3-2. Temporal Trends for TCE – November vs. May .....................................................13 Exhibit C. Remedial Goals for PCBs, Metals (Arsenic and Lead), and PAHs (See Table 3 for Reference Information) ................................................................................20 Exhibit 12-1. Project Schedule ..................................................................................................36 TABLES
Table 1. Polychlorinated Biphenyls (PCBs) in Soil
Table 2. Applicable or Relevant and Appropriate Requirements (ARARs) and To-be-considered Criteria (TBCs)
Table 3. Remedial Goals for Chemicals of Concern (COCs) in Soil Table 4. Targeted PCB Excavations
Table 5. Targeted Lead Excavations
Table 6. Off-Site Excavations
Table 7. Constituents Exceeding Residential Screening Levels
FIGURES
Figure 1. Site Location Map
Figure 2. Site Map
Figure 3. Pre-Delineation Sampling Distribution of PCBs in Soil Figure 4A. Post-Delineation Sampling Distribution of PCBs in Soil – Northern Areas Figure 4B. Post-Delineation Sampling Distribution of PCBs in Soil – Southern Areas Figure 4C. Proposed Target Lead Excavations
Figure 5. Proposed On-Site Excavation Plan
Figure 6A. Proposed Off‐Site Excavations – Northern Areas Figure 6B. Proposed Off‐Site Excavations – Southern Areas Figure 7. Proposed Confirmation Sampling Grid
APPENDICES
Appendix A. California Land Reuse and Revitalization Act (CLRRA) Agreement Appendix B1. Historical Table Summaries – Metals in Soil Appendix B2. Historical Table Summaries – PAHs in Soil
Appendix B3. Historical Table Summaries – PCBs in Soil
Appendix C. Historical Distribution of PCE in Soil Gas
Appendix D. Data from 2015 AMEC Investigation
Appendix E. Historical Off-Site Sampling Locations
Appendix F. Summary Table for PCB Delineation
Appendix G1. Soil Vapor Investigation Reports dated January 31, 2023 Appendix G2. Addendum to the Soil Vapor Investigation Report dated June 29, 2023 GSI Job No.: 6239
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RESPONSE PLAN
Former Riverside Scrap Iron & Metal Property
2993 6th Street
Riverside, California 92507
1.0 INTRODUCTION
On behalf of Iron Lofts LLC (Iron Lofts), GSI Environmental Inc. (GSI) has prepared this Response Plan based on the results of the Site Assessment and Report of Findings (Report of Findings) dated August 3, 2022, for the former Riverside Scrap Iron & Metal (RSIM) property located at 2993 6th Street in Riverside, California (the Site; Figures 1 and 2).
The Site has been the subject of numerous subsurface investigations, which have identified that shallow soil at the Site is impacted with polychlorinated biphenyls (PCBs), polycyclic aromatic hydrocarbons (PAHs), and metals (primarily lead and arsenic) at concentrations exceeding regulatory screening levels for residential use and/or regional background concentrations. In addition, VOCs have been detected in Site soil vapor at concentrations above residential screening levels.
This Response Plan will support the multi-family residential redevelopment of the Site by Iron Lofts.
1.1 Objectives of the Response Plan
The objectives of this Response Plan are to:
• summarize existing Site conditions , future land uses, completed investigation activities, and constituents of concern ( COCs) that were previously presented in the Report of Findings.
• establish appropriate remedial action objectives (RAOs) for protection of human health and the environment;
• evaluate alternatives and select remedial actions for the Site that are protective of human health and the environment; and
• provide a scope of work to implement the selected remedy at the Site.
1.2 Current Regulatory Status
A Revised Remedial Action Plan (RAP) for the Site, dated January 2, 2020, was prepared by GSI on behalf of the prior Site owner, RSIM, and submitted to DTSC to summarize additional activities completed at the Site and to propose a remedial action consisting of Excavation and Off -Site Disposal. The RAP was not implemented because the property was sold, and the current Site owner has entered into a California Land Reuse and Revitalization Act of 2004 (CLRRA) agreement with the Department of Toxic Substances C ontrol (DTSC) providing regulatory oversight (Appendix A). Based on the presence of PCBs at the Site, United States Environmental Protection Agency (USEPA) is providing supplemental regulatory oversight, specific to PCBs and requirements of the federal Toxic Substances Control Act (TSCA) , in coordination with DTSC .
The CLRRA agreement requires a Site Assessment and Report of Findings (Appendix A – Section
5.3) and a Response Plan (Appendix A – Section 5.4) . The Site Assessment and Report of Findings was submitted to DTSC on August 3, 2022. This Response Plan provides information required under Health and Safety Code (HSC) Section 25395.96 (a) and (b), included as Exhibit 1.1.
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Exhibit 1-1. Requirements of Health and Safety Code (HSC) Section 25395.96(a) and (b) (Agency-specific tasks identified with gray text)
HSC HSC Text Corresponding
Section of This
Report
25395.96(a)
If, upon review of the site assessment prepared pursuant to this article, the agency determines that a response action is necessary to prevent or eliminate an unreasonable risk, the bona fide purchaser, innocent landowner, or contiguous property owner shall submit a response plan to the agency to conduct a response action at the site, in conformance with the agreement entered into pursuant to Section 25395.92. The response plan shall include all of the following:
(1)
The response plan shall provide for an opportunity for the public, other agencies, and the host jurisdiction to participate in decisions regarding the response action, taking into consideration the nature of the community interest, and shall include all of the following:
(A) Thirty days before taking action pursuant to the response plan, the agency shall take all of the following actions:
(i) Notify all other appropriate governmental entities and local agencies, including, but not limited to, the department, the regional board, or a redevelopment agency, that is not a party to the response plan regarding the proposed response plan. (ii) Place a notice in a newspaper of general circulation, in the area of the site, including, but not limited to, a community-based newspaper, as appropriate. (iii) Post notice of the proposed response plan on the site. (B) All of the following methods for public participation shall be included in the response plan:
(i) Thirty days' prior public notice in a factsheet format of the proposed response plan, in English and in any other language commonly spoken in the area of the site. (ii) Access, at both the agency and at local repositories, to the proposed response plan, site assessment, addenda, and any other supporting documentation, including materials listed as references in the response plan and site assessment. (iii) Procedures for providing a reasonable opportunity to comment on the plan and related documents specified in clause (ii).
(iv) If a public meeting is requested, the holding of a public meeting by the agency in the area to receive comments.
(v) The agency's consideration of any comments received before taking any action regarding the response plan.
(C) The response plan may also provide for, but is not limited to, proposing the use of other methods for public participation, including the use of public notices, direct notification of interested parties, electronic copies of the response plan, site assessment addenda, and other supporting documentation, including materials listed as references in the response plan and site assessment, electronic comment forms, forming advisory groups, as appropriate, to disseminate information and assist the agency in gathering public input, additional public meetings or public hearings, and an opportunity to comment on the proposed response plan prior to approval.
(D) The agency, as part of its communications with affected communities, shall provide information regarding the process by which decisions about the site are made and the recourse that is available for those who may disagree with an agency decision. (E) The agency shall consider the issue of environmental justice, as defined in subdivision (e) of Section 65040.12 of the Government Code, for communities most impacted, including low-income and racial minority populations, before taking action on the response plan. (F) To the extent possible, the agency shall coordinate its public participation activities with those undertaken by the host jurisdiction and other agencies associated with the development of the property, to avoid duplication to the extent feasible. (G) It is the intent of the Legislature that the public participation process established pursuant to this paragraph ensures full and robust participation of a community affected by this chapter.
Section 10
(2) Identification of the release or threatened release that is the subject of the response plan and documentation that the plan is based on an adequate characterization of the site. Section 3 (3)
An identification of the response plan objectives and the proposed remedy, and an identification of the reasonably anticipated future land uses of the site and of the current and projected land use and zoning designations. This identification shall include confirmation by the host jurisdiction that the anticipated future land uses and current and projected land uses and zoning designations are accurate.
Section 1.1, Section 2,
and Section 5
(4) A description of activities that will be implemented to control any endangerment that may occur during the response action at the site. Section 8, GSI Job No.: 6239
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HSC HSC Text Corresponding
Section of This
Report
(5) A description of any land use control that is part of the response action. Section 8 (6) A description of wastes other than hazardous materials at the site and how they will be managed in conjunction with the response action. Sections 8.5 and 8.6 (7) Provisions for the removal of containment or storage vessels and other sources of contamination, including soils and free product, that cause an unreasonable risk. Sections 8.5 and 8.6 (8)
Provisions for the agency to require further response actions based on the discovery of hazardous materials that pose an unreasonable risk to human health and safety or the environment that are discovered during the course of the response action or subsequent development of the site.
Section 8.4
(9) Any other information that the agency determines is necessary N/A 25395.96(b) The agency shall evaluate the adequacy of the plan submitted pursuant to subdivision (a) and shall approve the plan if the agency makes all of the following findings:
(1) The plan contains the information required by subdivision (a). N/A (2)
When implemented, the plan will place the site in a condition that allows it to be used for its reasonably anticipated future land use without unreasonable risk to human health and safety and the environment.
N/A
(3) The plan addresses any public comments. N/A
(4) If applicable, the plan provides for long-term operation and maintenance, including land use and engineering controls, that are part of the remedy contained in the response plan. N/A N/A = Not Applicable
This Response Plan was developed in accordance with DTSC/CalEPA – Proven Technologies and Remedies Guidance Remediation of Metals in Soil, August 29, 2008 (DTSC, 2008).
Additionally, this R esponse Plan was prepared in a manner consistent with the federal Comprehensive Environmental Response Compensation and Liability Act (CERCLA, 42 U.S.C. 9601 et seq.), as amended; the National Contingency Plan (NCP, 40 Code of Federal Regulations [CFR] Part 300), as amended; applicable USEPA guidance (USEPA, 1988); and other applicable State and local laws and regulations.
2.0 SITE DESCRIPTION
The Site is approximately 7 acres in size and is identified as “light industrial” by the Riverside County Assessor’s Office . Surrounding properties are mixed commercial/residential and have historically been mixed commercial/residential/industrial in nature (Geomatrix, 2005). The Site is located within the former Marketplace Brownfields Study Area in the City of Riverside, bound by Commerce Street to the northwest, Mission Inn Avenue and 7th Street on the southwest, and by
4th Street on the northeast. The Marketplace Brownfields Study Area was comprised of 26 parcels that were grouped into 23 “Areas” based on parcel configuration ownership and current or historical use during a Phase I ESA (Geomatrix, 2005). This numbering system has been maintained for continuity . The RSIM Site includes only those areas owned or used by RSIM (Areas 8a‐8h, 10a, 10b, 12 of the Marketplace Brownfields Study Area). Redevelopment of the Site for multi-family residential use, similar to surrounding recent redevelopment projects is being planned. The current layout of the Site is shown on Figure 2.
2.1 Current and Historical Uses
The Site was used as a scrap metal recycling yard for over 45 years, and Site structures included a main office (Area 8a), a former machine shop (Area 8b), a storage building (Area 8d), and an office/maintenance building (Area 10a). The Site formerly maintained underground and aboveground storage tanks on the southwestern portion of the Site (Area 8e) that were used to store and dispense fuel and oil. Historical railroad operations were conducted in Areas 8f, 8g, and
12. The scrap metal and recycling business ceased operations in 2015. By August 2015, the Site had been cleared of utilities and most mixed trash, debris and scrap metal, and currently consists GSI Job No.: 6239
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mostly of unpaved bare earth and paved surfaces with some remaining debris. Surrounding land uses to the north and west are primarily commercial. Residential housing is located along the eastern border of the Site and across Mission Inn Avenue to the south.
2.2 Site Geology and Hydrogeology
The Site is located in the Riverside- Arlington Subbasin of the Upper Santa Ana River Groundwater Basin and within the Peninsular Ranges Geomorphic Province of California. The subbasin is bounded by the impermeable rocks on the south by Arlington Mountain, on the southeast by the Box Springs Mountains, on the northwest by the La Sierra Heights and Mount Rubidoux, and on the north by the Jurupa Mountains . The northeast boundary is defined as the Rialto-Colton fault, and a portion of the groundwater divide beneath the city of Bloomington and the Santa Ana River flows over the northern portion of the subbasin (Department of Water Resources [DWR], 2004).
Groundwater in the subbasin is dominantly found in young Quaternary-aged alluvial deposits from the lateral migration of the Santa Ana River over time and consists chiefly of sand, gravel, silt, and clay. The geology in the surrounding mountains and basement rock consists of Quaternary alluvium, Pleistocene nonmarine, and Mesozoic granitic rocks (California Division of Mines and Geology [CDMG], 1965). Soils beneath the Site consist primarily of silty sand and sandy silt with occasional thin layers of clay f rom near surface to 20 feet below ground surface ( bgs), the maximum depth of exploration (AMEC, 2015).
In December 2009, the depth to groundwater ranged from 114 to 125 feet bgs with a
southwestern groundwater gradient direction at the former Ken’s Arco property, located approximately 650 feet southeast of the Site at 2871 University Avenue (as reported by Pacific Edge Engineering, Inc. and referenced in AMEC’s 2015 Soil and Soil Vapor Investigation). Based on the general drought conditions since this measurement was taken, currently groundwater levels would be expected to be deeper than reported in December 2009.
2.3 Site Vicinity
The Site is surrounded by commercial, industrial and residential properties. The Riverside Downtown Train Station is located approximately 0.25 mile to the south-southwest of the Site.1 A 2019 investigation documented concentrations of tetrachloroethene (PCE) ranging to 4,000 ug/m3 in soil vapor samples at depths of 5 and 15 feet (Ninyo & Moore, 2020).
2.4 Site Development Plan
The Site is proposed to be developed with with two new multifamily buildings consisting of one four-story on-grade building and one two -story on-grade townhome building along the western portion of the Site. The buildings will consist of 50 studio units, 152 one- bedroom units, and 99 two-bedroom units (301 total units). Parking will include 378 residential surface parking spaces along with 10 garage parking spaces . The development plans include a lobby, leasing office, amenities, and a dog park. The northern parcel will not be developed at this time.
Iron Lofts has decided to include vapor intrusion mitigation systems (VIMS) at the future development. This will include installation, testing, and operation, maintenance, and monitoring (OM&M) of VIMS at the proposed building at the Site development. The VIMS will include:
1 https://www.envirostor.dtsc.ca.gov/public/profile_report.asp?global_id=60002763 GSI Job No.: 6239
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• Robust building slabs – buildings will be constructed with 10 .5-inch thick, post -tension slabs that are more resistant to cracking.
• Sub-slab venting (SSV) system – Horizontal soil-vapor collector and venting piping will be installed beneath the building slabs within a sand layer to collect and vent any VOCs in soil vapor from beneath the slab.
• VIMS – A spray -applied, composite membrane vapor barrier system will be installed directly beneath the building slabs and above the SSV system. The vapor barrier will be composed of a 40-mil spray-on membrane system placed between a geomembrane and protective layer. The vapor barrier system will extend beneath the entire building footprint, including building footings that are in contact with subsurface soil and utility penetrations and other slab penetrations to mitigate vapor migration pathways. • Utility penetration seals – utility penetrations through the building slab and sub-slab VIMS will be sealed as part of the VIMS installations (protocols for sealing utility penetrations will be described in the VIMS design drawings).
• Modern HVAC systems – the building HVAC systems will be programmed to maintain a balanced interior pressure, in accordance with building mechanical and energy codes, which will not induce vapor intrusion.
One existing historic building located at 3596 Commerce Street will be repurposed for use as amenity space. At this building, the existing crawl space will be vented passively with sub-slab venting (SSV), and the structure will be improved and built out, including installation of a modern HVAC system.
3.0 SITE CHARACTERIZATION
Site use as a scrap metal recycling yard for over 45 years has resulted in impact of COCs to the shallow subsurface. Site investigation and characterization has been conducted since 2011 to characterize the extent of impact at the Site resulting from historical operations.
3.1 Site Investigation
Site characterization activities have been conducted at the Site since 2011 and are summarized in the documents listed below.
• 2011 – Phase II Environmental Site Assessment, Ami Adini & Associates, Inc. • 2015 – Additional Phase II Environmental Site Assessment Report, Riverside Scrap Iron & Metal Site, AMEC Foster Wheeler
• 2017 – Off-Site Preliminary Environmental Assessment, Hillmann Consulting (Hillman) • 2018 – PCB Sampling and Analysis, GSI Site Assessment and Report of Findings (2022) • 2020 – Revised Remedial Action Plan, GSI
• 2021 – Phase I Environmental Site Assessment, Hillman • 2022 – Site Assessment Plan and Report of Findings, GSI • 2023 – Soil Vapor Investigations, GSI (Appendix G1 and G2) Data summaries for metals, PAHs, and PCBs in soil for all investigations are included in Appendix B. Soil vapor data and sample locations are identified in Appendix C. Off-Site sampling GSI Job No.: 6239
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locations are identified in Appendix E. Recent PCB delineation investigation results are identified in Appendix F.
In addition to the Site investigation documents listed above, a RAP dated January 2, 2020 and a Phase I Environmental Site Assessment dated September 21, 2022 have been completed for the Site.
3.1.1 2011 Phase II Investigation
In 2011, Ami Adini & Associates (AA&A) conducted a subsurface investigation at the Site (AAA, 2011). The investigation included the collection of 56 soil samples at depths of 0.5 to 1 -foot bgs and the deployment and collection of passive, GORE‐SORBER® soil vapor samples. Shallow soil samples were analyzed for total petroleum hydrocarbons (TPH), PAHs, PCBs, semi -volatile organic compounds (SVOCs), and metals. The passive soil vapor samples were analyzed for volatile TPH and VOCs.
Soil vapor analysis using GORE ‐SORBER® samplers identified volatile TPH and VOCs in soil vapor at depths of 0.5 to 1 foot below ground surface (bgs) at various locations across the RSIM Site; however, the passive soil ‐gas sampling technology used did not provide data suitable for comparison with risk‐based screening levels.
Shallow soil analytical results indicated that PAHs, including benzo[a]anthracene, benzo[b]fluoranthene, benzo(a)pyrene, dibenz[a,h]anthracene, and indeno(1,2,3-cd)pyrene were detected in several shallow soil samples at concentrations exceeding their respective residential screening levels. These PAHs were detected in soil across the Site; however, elevated PAH concentrations were detected primarily in the maintenance yard, scrap storage, roll -off bin storage, and machine shop areas.
PCB concentrations were detected in 35 samples across the Site. During this investigation, three locations reported PCB concentrations in excess of 50 mg/kg of PCBs (A8b-SB1, A8e-SB4, and A10b-SB4).
AA&A reported several metals (antimony, arsenic, beryllium, cadmium, cobalt, copper, lead, mercury, nickel and vanadium) at concentrations above residential screening levels and/or background. Arsenic was detected at concentrations between 12 and 166 milligrams per kilogram (mg/kg) in Areas 8c, 8f, and 8g. All other areas did not identify soil with arsenic above 12 mg/kg, the upper bound background concentration (DTSC, 2008) . Lead was detected in shallow soil at concentrations up to 4,260 mg/kg. Concentrations of other metals reported above the residential screening levels are generally co- located with elevated arsenic and lead concentrations at the Site.
Soil analytical result tables for metals, PAHs, and PCBs are included in Appendix B.
3.1.2 2015 Additional Phase II Investigation
In August‐October 2015, AMEC Foster Wheeler (AMEC) conducted a supplemental investigation at the property. AMEC indicated that the objectives of the additional Phase II sampling were to address data gaps (i.e., vertical and lateral extent of COCs in soil and soil vapor) to support preparation of a RAP to address known impacts to soil from operations related to scrap metal recycling at the Site. The objective was also to collect data on PCB concentrations in shallow soil near the boundary between the Site and adjacent residential properties and evaluate the potential need for characterization of PCBs in soil at these off-Site properties (AMEC, 2015).
A total of 22 borings were installed with soil sampling conducted at 0.25, 1, 2.5, 5, 10, and 15 feet bgs at most locations. The soil samples were analyzed for total petroleum hydrocarbons (TPH speciated in gasoline, diesel, and oil ranges), VOCs, metals, PCBs, PAHs, and SVOCs. The GSI Job No.: 6239
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borings were completed with soil vapor sampling probes installed at two depths: one at 5 feet bgs and one at 11‐15 feet bgs.
Overall, the results indicate the upper 1 foot of soil across the Site is impacted with lead, PCBs, and PAHs, which are present in concentrations that exceeded residential screening levels, with soil impacts extending deeper at some locations to 2.5 feet bgs. 2 COCs were only identified in excess of residential screening levels in one soil sample location deeper than 2.5 feet (NS20 in Area 8h). Soil in this area appears to have been disturbed historically and surficial soils may have been mixed into underlying soil at this location. Elevated TPH was identified in this area at the location of sample S8 at depths of up to 5 feet bgs. PCB concentrations in excess of 50 mg/kg of PCBs was reported at three locations (NS2, S14, and S6).
The soil vapor sampling results from 2015 identified relatively low concentrations of VOCs; however, trichloroethene (TCE) and PCE were detected in soil vapor at concentrations exceeding residential screening levels. 3 The maximum concentration of TCE ( 570 micrograms per cubic meter [µg/m3]) reported in soil vapor exceeded the residential screening levels for current (240 µg/m3) and future (480 µg/m3) land use. PCE was detected at a maximum concentration of 2,000 µg/m3, exceeding the residential screening levels for current (230 µg/m3) and future (460 µg/m3) land use. The analytical results for 2015 soil vapor samples are summarized in data tables and figures showing the distributions of PCE and TCE in soil vapor in Appendix C.
The AMEC investigation included a soil sampling program along the southeast property line, which borders four residential properties. The PCB concentrations in most fence line boring soil samples were in excess of residential screening levels, primarily at 0.25 feet bgs.
The results of the additional Site investigation indicated that the vertical and horizontal extent of lead, arsenic, and PAHs had been adequately characterized (on‐Site) to depths of less than 2.5 feet bgs, with the exception of the location of NS20 samples in Area 8h (AMEC, 2015). 4 In
addition, soil and soil vapor sampling results at the former ASTs and USTs suggest no significant impact to soil. The results of this work are presented in AMEC’s “Additional Phase II Environmental Site Assessment Report” dated December 9, 2015.
AMEC recommended no additional sampling, except for what may be required to characterize possible impact to the nearby residential properties.
Soil analytical results tables for metals, PAHs, and PCBs are included in Appendix B . Figures identifying AMEC sampling locations are included in Appendix D.
3.1.3 2017 Off-Site Preliminary Environmental Assessment To address possible impact to the off ‐Site residential properties, Hillmann prepared a Technical Memorandum (Tech Memo) proposing a scope of work for off ‐Site and perimeter soil sampling dated November 8, 2016. The proposed scope of work included sampling on the adjoining residential properties located along the southeast property line at 2981 Mission Inn Avenue, 2968 6 th Street, 2981 6th Street, and 2980 5th Street. In addition, the Tech Memo proposed testing of the soil just outside the Site perimeter, including near the pathways used by trucks that enter and exit the Site. This work was required by USEPA to determine if impacted material might have spread to greenway areas near the outer gat es of the parcels, a s these areas intersect with
2 USEPA Region 9 Regional Screening Levels for industrial and residential soil, June 2015. 3 USEPA Region 9 regional screening levels, June 2015, were adjusted for a default attenuation factor of 0.001 (DTSC, 2011)
4 Note that PCBs were further characterized (pre-remedial confirmation sampling) during the 2018 investigation in accordance with USEPA TSCA requirements (40 CFR 761.61).
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sidewalks and pathways accessible to the community. The Tech Memo was approved by DTSC by letter dated December 2, 2016.
To attempt to define the lateral extent of contamination on the off ‐Site residential properties, Hillmann proposed to advance eight soil borings on each of the four boundary residential properties, and a separate series of borings in boundary greenway areas. Prior to conducting the investigation, the RSIM property owner secured access to three of the four off ‐Site residences; the most northeastern property (2980 5th Street) did not grant access for the investigation.
In February 2017, Hillmann advanced a total of 40 soil borings at the locations proposed in the Tech Memo. Borings S1 through S24 were installed on the three residential properties where access had been permitted. These borings were installed along parallel lines to the property line and previous fence line borings. Each residential Site included soil borings installed approximately 3 and 10 feet from the property line, in accessible areas. The Site boundary borings were installed in accessible, non‐paved, greenway locations along the property easement with public right ‐of‐ way areas near the scrap yard driveways. Borings S25 to S28 were installed along the Mission Inn Avenue edge of the property; borings S29 to 33 were installed in access points along 5th Street and borings S34‐S40 were installed along 6th Street access points.
Investigation results from borings on the two southwest residential properties (2981 Mission Inn Ave. and 2968 6th Street) identified two locations at each property with lead concentrations greater than 80 mg/kg with a maximum concentration of 183 mg/kg in sample S1‐ 0.25. Sample S8‐0.25, located approximately 10 feet from the Site in line with boring S1, had a reported lead concentration of 95.5 mg/kg. Samples S9‐ 0.25 and S12‐ 0.25 (located at 2968 6th Street) had reported lead concentrations of 153 and 86.1 mg/kg, respectively. In addition, one sample collected approximately 10 feet from the fence line at 2968 6th Street had PAH concentrations in excess of residential screening levels, though none of the samples obtained closer to the fence line had reported concentrations of PAHs above residential screening levels. These results suggest that targeted remedial excavation to 1- foot bgs at these two sites could be reasonably completed with confirmation soil sampling used to ensure that the impacted soil had been adequately removed (Hillmann, 2017a).
Six soil samples collected at the 2981 6th Street residence (located just northeast of the other residences, ac ross 6th Street) reported COCs greater than residential screening levels. Five samples had lead concentrations greater than 80 mg/kg, including the 0.25‐ foot samples from borings S19, S20, S22, and S23. The highest lead concentration was detected in sample S20 ‐
0.25 at 976 mg/kg. This sample also contained PCBs slightly above residential screening levels with 0.25 mg/kg Aroclor 1260 (slightly exceeding the current 0.24 mg/kg residential screening level). Only one of the deeper samples collected at this property had COC concentrations in excess of the residential screening levels; sample S19‐1 had a reported lead concentration of 193 mg/kg. The deeper sample from this location, sample S19‐ 2.5, was subsequently analyzed for lead and the reported lead concentration was 6.54 mg/kg, defining the vertical extent of impacts in this area (Hillmann, 2017a).
The adjacent property located at 2980 5th Street could not be sampled because access was not granted. Prior to implementation of remedial actions outlined in this Response Plan, an additional attempt will be made to gain access to this property for soil sampling.
Soil analytical result tables for metals, PAHs, and PCBs are included in Appendix B and Sample locations are identified in Appendix E.
3.1.4 2018 Additional On-Site PCB Sampling and Analysis Procedures for conducting soil sampling for PCBs at the Site under TSCA were summarized in the Revised Technical Memorandum Workplan for Delineation of RCRA Level PCB-Impacted Soil GSI Job No.: 6239
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prepared by Hillman in October 2017 (PCB Work Plan; Hillmann, 2017b). GSI was subsequently retained in November 2017 by RSIM to implement the PCB Work Plan. In early December 2017, GSI, USEPA, and DTSC corresponded to confirm the TSCA procedures for delineation and removal of PCB-impacted soil.5
Six historical sample locations with PCB concentrations exceeding 50 mg/kg were identified in the PCB Work Plan for further characterization in accordance with TSCA requirements (Figure 3).
Additional soil sampling and analysis was conducted by GSI in 2018 to define the extent of PCB impacts in soil in these areas (Figures 4A and 4B) . Soil samples were collected on a 1.5 -meter grid pattern at stepped -out locations from the six identified locations, with samples from each location collected at depths from the surface (0.25 feet), 1.0, 2.5 and 5.0 feet bgs . Expansion of the grid continued until concentrations of PCBs equal to or greater than 50 mg/kg were defined vertically and laterally. Soil delineation “step out” sampling events were conducted accordingly on the following dates:
January 23, 2018;
May 18, 2018;
July 27, 2018;
August 3, 2018;
September 27, 2018; and
December 20, 2018.
During the six sampling events, soil samples were collected from approximately 115 step -out borings from the six locations where PCBs had been detected above 50 mg/kg in shallow soil (A10b-SB4, S14, A8b-SB1, A8e-SB4, S6, and NS2). Soil samples were collected at one or more depths of 0.5, 1, 2.5, and 5 feet bgs . In general, lateral (step-out) and vertical (deeper) samples were collected and placed on hold. If a primary sample reported PCB concentrations exceeding 50 mg/kg, then the corresponding step-out and/or deeper sample was analyzed.
The soil samples collected were analyzed for soil moisture using USEPA Method 9045D, and PCBs using USEPA Method 8082A and the Soxhlet extraction method USEPA Method 3540C .
Concentrations in soil samples were reported on a dry-weight basis as mg/kg, as indicated in the PCB Facility Approval Streamlining Toolbox (FAST; USEPA, 2017) . Soil analytical results are included in Appendix E.
After the December 20, 2018 sampling event, all six PCB -impacted areas were delineated laterally and vertically with the exception of one sample location (KK26), where concentrations of PCBs exceeded 50 mg/kg (Figure 4A). On February 5, 2019, USEPA and DTSC concurred that the Site was characterized for PCBs and that no further sampling was necessary to complete preparation of the RAP, and further, that confirmation soil sampling could be conducted in the area south of KK26 to document that remedial excavation goals for PCBs are met at that location. 6 Results of PCB-delineation sampling are included in Appendix F and on Figures 4A and 4B.
3.1.5 2020 Revised Remedial Action Plan
A RAP was completed for the Site on January 2, 2020. This document summarizes the nature and extent of contamination for the Site and provides a feasibility study that identifies remedial alternatives including: 1) No Further Action; 2) Containment through Surface Capping; or
5 In accordance with 40 CFR 761.61.
6 Conference call between GSI, RSIM, USEPA, and DTSC representatives and e-mail from USEPA dated February 8, 2019.
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3) Excavation and Off -Site Disposal . Alternative 3, Excavation and Off -Site Disposal, was selected as the remedy, and the RAP identified Site -wide excavation depths and targeted excavations based on COC concentrations that were compared to applicable residential screening levels. A Remedial Action Implementation plan was included in the RAP.
3.1.6 2021 Phase I ESA
A Phase I Environmental Assessment (ESA) was completed for the Site on September 21, 2021 (Hillman, 2021). Recognized environmental conditions (RECs) identified for the Site included the following:
The recommended response actions for the identified RECs are as follows:
The Phase I ESA RECs #1 and #2 both reference potential impact from low concentrations of petroleum hydrocarbons originating from former fuel USTs at the Site that were removed in the year 2000 in the vicinity of Area 8b (Figure 2). In August 2015, soil samples collected from depths of 2.5, 5, 15, and 20 feet below grade at a location approximately 10 feet south of the former UST excavation, were analyzed for VOCs, including gasoline-range organics, and no compounds were identified above the laboratory reporting limit in any sample collected. Additionally, gasoline-range organics were not identified in approximately 90 soil samples collected from depths between 2.5 and 20 feet at 46 locations across the Site (AMEC, 2015; Figure 2 and Table 4). Implementation
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of the proposed remedial action plan is contemplated to address shallow soil impacts above residential land use criteria.
3.2 2022 Site Assessment Plan and Report of Findings
The Site Assessment and Report of Findings (GSI, 2022) is required under the CLRRA agreement between Iron Lofts and DTSC that was entered into for redevelopment of the Site. Iron Lofts purchased the property after the 2020 RAP was submitted to DTSC. The Site Assessment and Report of Findings is a summary of the Site and Site investigations (listed in the Sections above) and presents information related to the nature and extent and contamination at the Site . Based on the historical data available for the Site, the Site Assessment and Report of Findings recommended the preparation of a Response Plan that will evaluate the alternatives for response actions necessary to “reduce COC concentrations to concentrations considered protective of human health for residential use.”
3.3 2023 Soil Vapor Investigation Reports
Soil vapor sampling was completed at locations throughout the Site in November 2022 and May 2023 to evaluate PCE and TCE in soil vapor and provide the additional assessment data required to support the planned multifamily redevelopment planning, design, and regulatory oversight, and for the evaluation of unrestricted Site use. The Soil Vapor Investigation Report and Addendum to the Soil Vapor Investigation Report have been included as Appendix G.
Analytical results for soil vapor samples are evaluated by comparison to risk -based screening levels for residential and commercial/industrial Site use. Screening levels for soil vapor are developed by applying an attenuation factor to screening levels for indoor air:
Soil Vapor Screening Level (SLsv)= SLia
AF
Where:
SLsv = Soil vapor screening level (µg/m3)
SLia = Indoor air screening level (µg/m3)
AF = Attenuation factor (unitless)
Soil vapor screening levels were calculated using the default attenuation factor published by DTSC for residential and commercial use (0.03; DTSC & State Water Resources Control Board [SWRCB], 2023); these soil vapor screening levels are referred to in this report as the “DTSC - SLs.” Soil vapor data are evaluated by comparison to the DTSC -SLs for an initial screening of soil vapor data.
As shown in Appendix G, PCE, TCE, 1,2-dichloroethene (1,2-DCA), and chloroform were the only VOCs detected in at least one soil vapor sample at a concentration exceeding its DTSC-SL, and the results for these VOCs are summarized below:
• PCE was detected in all soil vapor samples collected at concentrations ranging from 63 to 850 µg/m3. The highest PCE concentrations in soil vapor were observed in the soil vapor samples collected at 30 feet bgs at the southwestern and northeastern property boundary of the southern parcel ( 850 µg/m3 at VP-1-30 REP, 810 µg/m3 at VP-1-30, 640 µg/m3 at VP-9-30, and 840 µg/m3 at VP-19-30) and southeastern property boundary of the central parcel (780 µg/m3 at VP-20-30). All soil vapor samples exceed the DTSC-SL of 15 µg/m3. • TCE was detected in 22 of 23 total soil vapor samples at concentrations ranging from 6 to 2,100 µg/m
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vapor samples with the highest PCE concentrations. Specifically, TCE was detected at the highest concentrations in the soil vapor samples collected at 30 feet bgs at the southwestern and northeastern property boundary of the southern parcel (2,000 µg/m3 at VP-1-30 REP and 1,900 µg/m 3 at VP-1-30, 1,600 µg/m3 at VP-9-30, and 1,700 µg/m3 at VP-19-30) and southeastern property boundary of the central parcel ( 2,100 µg/m3 at VP- 20-30). All soil vapor samples with detections of TCE except for one (6 µg/m3 at VP-9-5) exceed the DTSC-SL of 16 µg/m3.
• 1,2-DCA was detected in one soil vapor samples at a concentration of 17 µg/m3, which exceeds the DTSC -SL of 3.7 µg/m3. The low concentration of 1,2 -DCA was not reproduced in any other soil vapor samples collected in 2022 and 2023. • Chloroform was detected in four soil vapor samples at concentrations ranging from 19 to 24 µg/m3, all of which exceed the DTSC-SL of 4.0 µg/m3. Chloroform is commonly detected in soil vapor samples since chloroform is a disinfection byproduct and present in municipal water (Agency for Toxic Substances and Disease Registry [ATSDR], 1997).
During the November 2022 sampling event, 47 primary soil vapor samples were collected from 21 locations installed at depths ranging between 5 and 30 feet. During the May 2023 sampling event, 23 primary soil vapor samples were collected from 8 of the locations previously identified with higher concentrations of PCE and/or TCE relative to the other probes at the Site. PCE and TCE were the primary VOCs detected in soil vapor samples during both sampling events. PCE was detected in every soil vapor sample, but at relatively low concentrations (up to 85 0 µg/m3).
TCE was detected less frequently, but at slightly higher concentrations (up to 2,100 µg/m3).
In general, PCE and TCE concentrations during the November 2022 sampling event increased with depth at all soil vapor sample locations (i.e., higher concentrations were detected in deeper soil vapor samples) with the exception of two locations (VP -4 and VP-5). The highest PCE and TCE concentrations in soil vapor were observed from soil vapor samples collected at 30 feet bgs at the southwestern and northeastern property boundary of the southern parcel and southeastern property boundary of the central parcel . The results of the May 2023 sampling event were consistent with the November 2022 sampling event.
The results of the November 2022 sampling event were compared to the results of the May 2023 sampling event to evaluate the temporal variability of PCE and TCE in soil vapor at the Site.
Results presented in the Addendum to the Soil Vapor Investigation Report and in Exhibit A and B, below and discussed further in the Addendum, do not indicate any significant temporal variation in PCE or TCE concentrations between the November 2022 and May 2023 data.
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Exhibit 3-1. Temporal Trends for PCE – November vs. May
Exhibit 3-2. Temporal Trends for TCE – November vs. May
0 100
200
300
400
500
600
700
800
900CONCENTRATION (µg/m3)
5/18/2023 11/16/2022
0 500
1000
1500
2000
2500CONCENTRATION (µg/m3)
5/18/2023 11/16/2022
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Thus, only low concentrations of PCE and TCE were detected in soil vapor samples collected and analyzed during the November 2022 and May 2023 sampling events . The analytical results for soil vapor samples collected in November 2022 and May 2023 also are generally consistent with soil vapor sampling results from 2015. PCE and TCE were detected at concentrations up to 2,000 and 570 µg/m3, respectively, in samples collected in 2015 (Appendix C), which is slightly greater than the range for PCE and less than the range for TCE detected in 2022 and 2023. These low concentrations are stable, as similar PCE and TCE concentrations were observed in November 2022 and May 2023. Although the possibility of small on- Site releases of PCE and TCE cannot be ruled out, the soil vapor results are consistent with an off-Site source of PCE and TCE.
4.0 NATURE AND EXTENT OF CONTAMINATION
Site use as a scrap metal yard for over 45 years has resulted in impact of COCs to the shallow subsurface. Soil sampling has identified PCBs, metals (arsenic and lead), and PAHs in shallow soil at concentrations above USEPA and DTSC -recommended residential screening levels . In addition, VOCs have been detected in Site soil vapor at concentrations above residential screening levels. However, the concentrations detected are relatively low and a lthough the possibility of small on-Site releases of PCE and TCE cannot be ruled out, the soil vapor results are consistent with an off -Site source of PCE and TCE. Minor releases of VOCs, most notably PCE and TCE, associated with historical Site use, also may be a source of VOCs in on- Site soil vapor. Based on historical Site investigation results, groundwater does not appear to have been impacted by COCs in shallow soil at the Site.
4.1 Soil
COCs (PCBs, metals, and/or PAHs) in soil are present within the top approximately 1 foot of soil across the Site, with a few detections at depths of 2.5 or 5 feet . Historical sample locations with concentrations of COCs that exceed screening levels are identified in Table 7 and Figure 7.
Although the specific source(s) of contamination at the Site have not been identified, the historical Site use as a scrap yard is considered the likely source of impact.
PCBs identified at the Site primarily include Aroclors 1242, 1248, 1254, and 1260. These Aroclors are commonly found in hydraulic fluid and polyvinyl acetate (paints and adhesives). The following table summarizes some potential sources for each of the Aroclors identified at the Site, some of which may be associated with historical Site operations. 7 Exhibit C. Potential Sources for Aroclors Identified at the Site Aroclor Potential Source
1242
Carbonless copy paper
Gas transmission turbines
Heat transfer
1248 Epoxy resins - Increased resistance to oxidation and chemical attack; better adhesive properties 1254
Capacitors
Chlorinated rubber - Enhanced resistance, flame retardant, electrical insulation properties Cutting oils
Ethylene vinyl acetate – Pressure-sensitive adhesives
Inks
Pesticide extenders
Sealants and caulking compounds
Styrene-butadiene co-polymers
7 https://www.oregon.gov/deq/FilterDocs/ph-SourcePCBs.pdf GSI Job No.: 6239
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Synthetic resins
1260 Polyester resins - Stronger fiberglass; reinforced resins and economical fire retardants Varnish - Improved water and alkali resistance
Multiple Aroclors Potential Source
1242, 1248 Rubbers
1242, 1248, 1254, 1260 Hydraulic fluid
1242, 1248, 1254, 1260 Polyvinyl acetate - Improved quick-track and fiber-tear properties 1242, 1254 Wax extenders
1242, 1254, 1260 Transformers
1248, 1254 Vacuum pumps
1254, 1260 Dedusting agents
4.2 Soil Vapor
Soil vapor sampling completed across the Site in 2015, 2022 and 2023 indicate that PCE and TCE concentrations generally increase to the total depth explored of 30 feet (i.e., higher concentrations were detected in deeper soil vapor samples) . Only low concentrations of VOCs were detected in soil vapor samples collected at the Site, and no VOCs were detected in soil vapor samples collected at depths of 5 to 15 feet bgs at concentrations exceeding 1,000 µg/m3.
The highest PCE and TCE concentrations in soil vapor were observed from soil vapor samples collected at 30 feet bgs at the southwestern and northeastern property boundary of the southern parcel and southeastern property boundary of the central parcel.
For soil vapor samples collected in 2022 and 2023, only low concentrations of PCE and TCE were observed in shallow soil vapor samples, with higher concentrations observed in soil vapor samples collected at 22 to 30 feet bgs:
Exhibit B. 2022 and 2023 Maximum Concentrations of PCE and TCE by Depth (µg/m 3)
PCE TCE
Maximum Detected Concentration (All depth) 850 2,100
Soil Vapor Samples collected at 5 feet bgs 280 190
Soil Vapor Samples collected at 13 to 15 feet bgs 460 770 Soil Vapor Samples collected at 22 to 30 feet bgs 850 2,100
These results indicate that the primary source of PCE and TCE to soil vapor is associated with an off-Site release of PCE and TCE, and that PCE and TCE concentrations decrease in shallow soil vapor compared to deeper soil vapor.
• Thorough soil and soil vapor sampling investigations were completed and a source of PCE or TCE to soil vapor was not identified on the Site.
• Concentrations increase with depth at all resampled soil vapor sample locations (i.e., higher concentrations were detected in deeper soil vapor samples). • The highest PCE and TCE concentrations in soil vapor were observed from soil vapor samples collected at 30 feet bgs at the southwestern and northeastern property boundary of the southern parcel and southeastern property boundary of the central parcel.
Analysis of three rounds of soil vapor investigation does not identify a source of PCE and TCE at the Site. Additionally, no evidence of significant temporal variability in concentrations of PCE or TCE is identified in the samples analyzed from 2015 to 2023. Low concentrations of PCE and TCE detected in soil vapor samples and increasing concentrations with depth are not indicative GSI Job No.: 6239
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of an on-Site release. It is possible that the low concentrations are attributed to minor releases associated with historical on-Site operations and/or an off-Site release that is migrating in deeper soil vapor or groundwater to the Site.
5.0 CONCEPTUAL SITE MODEL
A Conceptual Site Model (CSM) presents information about Site conditions and potential impacts to receptors (DTSC, 2015).
COCs (PCBs, metals, and/or PAHs) in soil are present within the top approximately 1 foot of soil across the Site. PCBs were detected at concentrations exceeding residential screening levels in soil samples collected primarily in the upper 1 foot of soil, and at a few locations at depths up to
2.5 or 5.0 feet bgs the Site (Table 1). Based on historical Site investigation results, deeper soils and groundwater do not appear to have been impacted by historical operations at the Site, and co-solvency of PCBs with other COCs at the Site is not suggested from the extensive sampling and limited vertical extent of PCBs in soil.
PCE and TCE have been detected in soil vapor at concentrations exceeding residential DTSC - SLs. In general, PCE and TCE concentrations in soil vapor are low and no specific source areas have been identified. It is anticipated that remedial soil removal will be performed as the initial step for residential Site redevelopment, which is expected to remove some concentrations of these VOCs in shallow soil.
Potential Contaminant Sources
Although the specific source(s) of contamination at the Site have not been identified, the historical Site use as a scrap yard is considered the likely source of PCBs, metals, and PAHs in shallow soil. A source of PCE or TCE to soil vapor was not identified on the Site and the low concentrations of PCE and TCE detected in soil vapor samples and increasing concentrations with depth are not indicative of an on-Site release. It is possible that the low conc entrations are attributed to minor releases associated with historical on-Site operations and/or an off-Site release that is migrating in deeper soil vapor or groundwater to the Site.
Potential sources of COCs in soil from the scrap yard operations for 45 years could include older electrical equipment; cable/wire insulation; oil used in motors and hydraulic systems; demolition waste; fluorescent light ballasts; caulk; water proofing materials; asphalt roofing materials; thermal insulation material including fiberglass, felt, foam, and cork; adhesives and tapes; oil-based paint; old electrical devices; appliances containing PCB capacitors; and metal composite siding or roofing materials.
Potential Contaminant Release and Transport
• COCs were released at the Site associated with the historical use of the Site as a scrap yard, primarily on unpaved surfaces and with trucks and heavy equipment moving scrap around the yard.
• COCs at the Site are primarily present within the top approximately 1 foot of soil . At few locations, PCBs in soil above remedial goals extend past 1 foot to 2.5 or 5.0 feet bgs.
• Based on historical Site investigation results, deeper soils or groundwater do not appear to have been impacted by historical operations at the Site and co -solvency of PCBs with other COCs at the Site is not suggested from the limited vertical extent of PCBs in soil. • Soil vapor sampling at the Site indicate the presences of low concentrations of volatile COCs that are likely associated with an off-Site source.
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Potential Receptors
The following receptors or users of the Site are identified for the current and future scenarios:
• Current Land Use – The Site is currently vacant, unused, and fenced. Based on current land use at the Site, a commercial worker, occasional Site visitor, and maintenance worker are the only current potential receptor populations identified. • Future Land Use – Residential development of the Site is planned. Consistent with DTSC PEA Guidance Manual, a hypothetical baseline (residential) scenario will be considered to determine whether restrictions on development of the Property are warranted to protect human health without further environmental actions.
Potential Exposure Pathways
Exposure pathways are considered “complete” for a particular receptor scenario when it can be demonstrated that a receptor may reasonably be expected to have the potential to come in contact with contaminants in certain environmental media (e.g., surface soils).
The primary exposure pathway identified for the Site is direct contact with the shallow soil. Under current land use, the Site is mostly unpaved and on-Site commercial/industrial workers have the potential to be exposed to contaminants in soil via incidental ingestion of soil, dermal contact with soil, and/or inhalation of particulates and volatile chemicals. Currently, the Site is vacant and not used for commercial/industrial or any other purposes. A hypothetical future resident may also contact soils if t he Site is redeveloped. Note that residential redevelopment likely would involve multi-family units, which would limit contact with soils. However, as a conservative evaluation and in accordance with DTSC PEA guidance, future Site use is assumed to include a residential development with unpaved areas. Thus, potential soil exposures by a future commercial worker, current maintenance worker, and hypothetical resident will be evaluated in an HHRA following implementation of this Response Plan.
Future receptors also may come into contact with VOCs detected in soil vapor via the vapor intrusion pathway. Several lines of evidence indicate that vapor intrusion does not pose an unacceptable health risk to future residents at the Site.
1. The highest PCE and TCE concentrations in soil vapor were observed from soil vapor samples collected at 30 feet bgs at the southwestern and northeastern property boundary of the southern parcel and southeastern property boundary of the central parcel.
2. PCE and TCE concentrations in soil vapor were delineated laterally during the following three sampling events:
o 2015 (22 locations; 44 samples analyzed) – Soil vapor samples collected from depths of 5 and 15 feet.
o 2022 (21 locations, 49 samples analyzed) – Soil vapor samples collected from depths of 5 and 15 feet. Deeper soil vapor samples were additionally collected from depths of up to 30 feet from 6 locations.
o 2023 (8 locations; 23 samples analyzed) – Soil vapor sample collection and analysis was duplicated at eight locations that were originally sampled in 2022.
3. A source of PCE or TCE to soil vapor was not identified on the Site and the low concentrations of PCE and TCE detected in soil vapor samples and increasing concentrations with depth are not indicative of an on-Site release. No VOCs were detected in soil vapor samples collected at depths of 5 to 15 feet bgs at concentrations exceeding 1,000 µg/m 3 in samples collected in
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associated with historical on- Site operations and/or an off -Site release that is migrating in deeper soil vapor or groundwater to the Site.
4. Consistently, low concentrations of VOCs were observed in soil vapor over an approximately 8-year soil vapor sampling period, indicating that VOC concentrations are stable in soil vapor.
5. Based the lines of evidence listed above, mitigation measures may not be needed to address the potential for low concentrations of PCE and TCE detected in soil vapor to migrate to indoor air at the Site development. However, as described in Section 2.4, Iron Lofts has decided to include the installation and operation of a VIMS at the proposed building at the Site development, and the planned VIM S will be constructed with features that will minimize the potential for vapor intrusion.
The lines of evidence described above apply to the vapor intrusion pathway evaluation at the existing historical building located at 3596 Commerce Street . As part of the repurposing of the existing historic building for use as amenity space, existing crawl spaces will be vented passively, and the structure will be improved and built out, including installation of a modern HVAC system.
Following completion of building improvements, indoor air samples will be collected to confirm the effectiveness of the vapor mitigation measures.
As part of the HHRA that will be completed following implementation of this R esponse Plan, potential vapor intrusion exposures by future receptors will be evaluated for completeness.
6.0 REMEDIAL ACTION OBJECTIVES
RAOs define qualitative goals and quantitative levels of cleanup and are based on a future residential land use of the Site.
6.1 Remedial Action Objective for Soil
Site characterization has identified the presence of COCs in soil at the Site. The development of several multi-story residential buildings following completion of the remedial activities are outlined in this Response Plan. The RAOs for this Site is based upon the current environmental conditions and the current and reasonably anticipated future uses of the Site:
1. Reduce COC concentrations in soil to concentrations considered protective of human health for residential use.
2. Prevent volatile COCs in soil vapor from migrating to indoor air at concentrations exceeding DTSC-SLs at on-Site buildings (i.e., future Site redevelopment buildings and the historic existing building).
Based on the RAO, cleanup goals were developed that establish specific concentrations of chemicals in environmental media that are protective of both human health and the environment.
6.2 Applicable or Relevant and Appropriate Requirements and To Be Considered Criteria
In addition to evaluating the technical aspects of various options for their suitability as potential remedial action alternatives, environmental laws and regulations must be reviewed to determine whether the option meets the environmental requirements. These applicable or relevant and appropriate requirements ( ARARs) are developed under the CERCLA process guidance. The following section presents an overview of the ARARs process and identifies ARARs affecting the RAOs. Additional "to be considered" (TBC) criteria that are meant to complement the use of ARARs are presented herein.
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6.2.1 Overview of ARARs
Identification of ARARs is a S ite-specific determination involving a two- part analysis: first, a determination of whether a given requirement is applicable; then if it is not applicable, whether it is relevant and appropriate. Applicable requirements are those cleanup standards, standards of control, and other substantive environmental protection requirements, criteria, or limitations promulgated under federal or state law that specifically address the situation at a particular site.
The requirement is appl icable if the jurisdictional prerequisites of the standard show a direct correspondence when objectively compared to the conditions at the Site. If the requirement is not legally applicable, then the requirement is evaluated to determine whether it is relevant and appropriate. Relevant and appropriate requirements are those cleanup standards, standards of control, and other substantive environmental protection requirements, criteria, or limitations promulgated under federal or state law that, while not applicable, address problems or situations sufficiently similar to the circumstances of the proposed response action and are well suited to the conditions of a site (USEPA, 1988). A requirement must be substantive in order to constitute an ARAR for activities conducted on- Site. Procedural or administrative requirements, such as permits and reporting requirements are not ARAR s. ARARs are promulgated, or legally enforceable federal and state requirements.
A summary of the potential ARARs that may pertain to the proposed remedial alternatives for the Site is included in Table 2.
6.2.2 Overview of TBC Criteria
TBC criteria includes non-promulgated criteria, advisories, guidance, and proposed standards issued by federal or state governments. Because TBC criteria are not potential ARARs, they are neither promulgated nor enforceable, and their identification and use are not mandatory. Rather, TBC criteria are meant to complement the use of ARARs, not to compete or replace them. For instance, many ARARs have broad performance criteria but do not provide specific instructions for implementation and those instructions are contained in supplemental program guidance. It may be necessary to consult TBC criteria to interpret ARARs, or to determine preliminary remediation goals when ARARs do not exist for particular contaminants.
A summary of the potential TBC criteria that may pertain to the proposed remedial alternatives for the Site is included in Table 2.
6.3 Remedial Goals
Results of previous Site investigations suggest that historical operations have generally impacted the shallow soil with PCBs, metals (arsenic and lead), and PAHs at concentrations above DTSC- SLs.
To achieve the established RAO, risk -based screening levels and regional estimates for background threshold values were selected as remedial goals.
The table below and Table 3 presents the remedial goals identified for Site COCs, including:
1. DTSC-SLs for residential soil, which are the lower (more conservative) of the values published by USEPA in the RSL tables (USEPA, 2022) and DTSC in HHRA Note 3 (2022b);
2. Background threshold values established for arsenic and carcinogenic PAHs (as benzo[a]pyrene equivalent) in soil, by the DTSC (2009, 2020); and GSI Job No.: 6239
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3. San Francisco Bay Regional Water Quality Control Board (SFRWQCB 2019). Environmental Screening Levels (ESLs) for TPH.
Individual PAHs will be evaluated in the upcoming health risk assessment in accordance with the HHRA Note 4 (DTSC, 2022a).
Exhibit C. Remedial Goals for PCBs, Metals (Arsenic and Lead), and PAHs (See Table 3 for Reference Information)
COC Residential Remedial Goal (mg/Kg)
Metals
Arsenic 12
Lead 80
Polycyclic Aromatic Hydrocarbons (PAHs)
Benz[a]anthracene 1.1
Benzo(b)fluoranthene 1.1
Benzo[a]pyrene 0.11
Benzo[a]pyrene Equivalents 0.9
Dibenz[a,h]anthracene 0.028
Indeno(1,2,3-cd)pyrene 1.1
Naphthalene 2
Polychlorinated Biphenyls (PCBs)
Aroclor 1016 4.0
Aroclor 1221 0.2
Aroclor 1232 0.17
Aroclor 1242 0.23
Aroclor 1248 0.23
Aroclor 1254 0.24
Aroclor 1260 0.24
Notes:
DTSC = California Department of Toxic Substances Control mg/kg = milligram per kilogram
US EPA = United States Environmental Protection Agency
See Table 3 for References.
6.4 Areas Exceeding Remedial Goals
Areas where COCs exceed remediation goals are identified based on Site investigation data .
Figures 4A, 4B, and 4C identify areas of targeted excavations for PCBs and lead at concentrations that require special handling ( Total PCB at concentrations ≥ 50 mg/kg and lead at either ≥1,000 mg/kg or ≥5 mg/L soluble lead using the Waste Extraction Test [WET]). Figure 5 identifies the overall Site excavation including COCs in soil at concentrations exceeding remedial goals identified in Table 3. Figures 6A and 6B identify the overall excavation plan for off-Site residential properties.
COC concentrations reported in confirmation samples collected during planned excavation activities will be compared to the remedial goals identified in Table 3 . For screening purposes, GSI Job No.: 6239
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the maximum concentration will be compared to remedial goals. Consistent with USEPA guidance (2002), the 95 percent upper confidence limit (95UCL) on the arithmetic mean of concentrations reported in confirmation samples will also be calculated to confirm that post-excavation conditions are protective of human health. According to USEPA (1989), although the 95UCL “does not reflect the maximum concentration that could be contacted at any one time, it is regarded as a reasonable estimate of the concentration likely to be contacted over time. This is because in most situations, assuming long-term contact with the maximum concentration is not reasonable.” This evaluation is consistent with the planned redevelopment of the Site with multi -story residential buildings. At DTSC’s request, the results of this evaluation will be confirmed with additional shallow soil samples at locations selected in collaboration with DTSC.
7.0 SUMMARY OF FEASIBILITY STUDY
The purpose of this Section of the Response Plan is to identify and screen possible remedial action alternatives (RAA) that may best achieve the RAO. This analysis was performed in accordance with the Guidance for Conducting Remedial Investigations and Feasibility Studies Under CERCLA (USEPA, 1988) and the nine evaluation criteria (40 CFR 300.430(e) (9)(iii)) of the NCP. The purpose of the analysis is to provide decision makers with sufficient information for comparing RAAs and selecting the preferred RAA for the Site. Selected RAAs must be protective of human health and the environment, cost‐effective, use permanent solutions and alternative treatment technologies to the maximum extent practicable, and satisfy the preference for treatment that reduces toxicity, mobility and/or volume as a principal element.
The nine evaluation criteria outlined in the NCP are the basis for conducting the detailed analysis. The criteria have been developed to meet the five statutory requirements of CERCLA Section 121, and technical, cost and institutional considerations that are considered important and appropriate for selecting RAAs. The nine evaluation criteria to be used in the detailed analysis of RAAs are listed below:
Threshold Criteria:
1. Overall protection of human health and the environment;
2. Compliance with ARARs;
Primary Balancing Criteria:
3. Long‐term effectiveness and permanence;
4. Reduction of toxicity, mobility, and/or volume of hazardous constituents;
5. Short‐term effectiveness;
6. Implementability;
7. Cost;
Modifying Criteria:
8. State acceptance; and
9. Public acceptance.
It is anticipated this Response Plan will be acceptable to the State based on discussions with DTSC and prior approval of the RAP; however, the final two criteria, State acceptance and public acceptance, cannot be fully evaluated at this time. These criteria consider the concerns of the State (technical and administrative) and public regarding the alternatives. The final two criteria GSI Job No.: 6239
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(Criteria 8 and 9) are usually evaluated following public comment on the Response Plan. These criteria are usually addressed when the DTSC makes its final remedial decision.
The nine criteria provide a uniform platform by which the technical and administrative merits of each RAA can be measured and are grouped into the following categories: “threshold criteria,” “primary balancing criteria,” and “modifying criteria.” The RAAs are further evaluated against a set of specific questions and considerations (“analysis factors”) that complement the analysis factors.
Any selected RAA must meet the threshold criteria and also be cost effective. Cost effectiveness is determined by examining whether the costs are proportional to the overall effectiveness of the remedy, as determined by evaluating the following three of the five primary balancing criteria: long‐term effectiveness and permanence; reduction of toxicity, mobility, and/or volume through treatment; and short‐term effectiveness. In addition, each RAA selected must accomplish permanent solutions to the maximum practicable extent. The following paragraphs briefly describe the factors addressed by each evaluation criterion.
Threshold Criteria. The overall protection of human health and environment, and compliance with ARARs are the two threshold criteria that a RAA must meet. Criterion 1 serves as a final check to assess whether a RAA provides adequate protection of human health and the environment.
Criterion 1 ‐ Overall Protection of Human Health and the Environment. This criterion assesses whether each RAA meets the short‐term and long‐term requirement for overall protection of human health and the environment from unacceptable risks posed by the hazardous substances, pollutants, or contaminants present in the groundwater at the Site. The following factors are considered when evaluating alternatives against Criterion 1:
• How the alternative provides human health and environmental protection:
o The level of protection to public health achievable, including the extent to which each alternative attains, exceeds or does not achieve ARARs or remedial action goals.
o Potential for migration of harmful by‐products into air and water during the Site remediation work.
• Potential environment impact from implementation of the alternative:
o Impacts on the surrounding community, including but not limited to heavy truck traffic, noise, odors, and other aesthetic considerations. o Potential impacts to surface water from implementation of the alternative; including impacts on storm water run‐off, soil erosion, and leaching. o Potential impacts to groundwater from implementation of the remedial action. o Potential restrictions on future uses of the Site after remedial action.
Criterion 1 is met if the RAA achieves the RAOs.
Criterion 2 ‐ Compliance with ARARs. Criterion 2 is used to determine whether the RAA meets chemical‐, action‐, and location‐specific ARARs previously identified above. This criterion is used to determine how effectively a RAA complies with the ARARs or, if a waiver is required because the ARARs cannot be met, how the waiver is justified. This assessment also addresses other advisories and guidance documents (TBCs).
Primary Balancing Criteria. The detailed analysis is based upon five primary balancing criteria which include long‐term effectiveness and permanence, reduction of toxicity, mobility, and mass, GSI Job No.: 6239
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short‐term effectiveness, implementability, and cost. Descriptions and analysis factors of the five primary balancing criteria against which the alternatives are evaluated, are discussed in the subsequent sections.
Criterion 3 ‐ Long‐Term Effectiveness and Permanence. This criterion considers the risk remaining at the Site after RAOs have been met and maintaining overall protection of human health and environment. Two major factors are considered: magnitude of residual risk and adequacy and reliability of controls. Magnitude of residual risk refers to risk remaining from untreated waste or treatment residuals. Adequacy d reliability of controls refers to the controls, if any, that are used to manage the residual risk identified. Technical components and institutional controls are evaluated, and, if a technical component needs replacement, the risk posed is also considered. The various remediation options have different levels of residual risk.
The No Action RAA has the highest potential risk of residual chemicals in soil since no active contaminant reduction is considered.
Criterion 4 ‐ Reduction of Toxicity, Mobility, and/or Volume of Hazardous Constituents.
This criterion addresses how well the RAAs permanently and significantly reduce the toxicity, mobility, and/or volume of the hazardous substances. The evaluation based on this criterion focuses on the quantity of hazardous materials removed, destroyed or treated, the degree to which the remedial action is irreversible, the type and quantity of residuals that are remaining after the RAA is complete, and whether the RAA satisfies the statutory preference for treatment as a principal element of the remedy.
Criterion 5 ‐ Short‐term Effectiveness. Each alternative is evaluated based on its effectiveness in protecting human health and the environment during the construction and implementation period. The short‐term effectiveness evaluation for each RAA focuses on protection to the Site workers and to the community during the construction and implementation phases of the RAA. The implementation phase is defined as the period of time required until the RAOs are met. The evaluation period will vary for each RAA.
Criterion 6 ‐ Implementability. The implementability criterion includes both the technical and administrative feasibility of implementing a RAA. The technical feasibility refers to the ability to construct, reliably operate and maintain, and meet the cleanup levels for the proposed process options. Administrative feasibility refers to the ability to obtain approvals from other state and local offices and agencies; the availability and capacity of treatment, storage, and disposal services; and the availability of specific equipment and technical specialists.
The following factors are considered:
• ability to construct and operate the technology;
• Site considerations that may affect the remedial action (e.g. on‐Site structures, drainage features);
• off‐Site conditions and external considerations (e.g. rights‐of‐way, access, availability of land and equipment);
• reliability of the technology;
• ease of undertaking additional remedial actions, if necessary; • ability to monitor effectiveness of the remedy;
• ability to obtain approvals from other agencies;
• coordination with other agencies;
• availability of off‐Site treatment, storage and disposal services, and capacity; • availability of necessary equipment and trained personnel; GSI Job No.: 6239
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• transportation requirements; and
• Site security.
Criterion 7 ‐ Cost. The cost criterion includes capital costs and operating and maintenance (O&M) costs. Capital costs include direct expenses, such as construction, equipment, and disposal costs, and indirect expenses, such as engineering and design, legal and permitting, mobilization and start‐up, and scope and bid contingency costs, as well as the costs of health and safety considerations and services during construction. Scope contingencies cover changes that invariably occur during final design and implementation and are intended to adjust the estimate so it can be used for budgetary purposes. Bid contingencies may cover unknown expenses associated with constructing a given project scope such as adverse weather conditions, geotechnical unknowns, and unfavorable market conditions for a particular project scope. O&M costs, calculated on an annual basis, include expenses for operating labor and materials, maintenance labor and parts, power requirements, sampling and analysis, administration, and periodic Site reviews.
The final costs of the project will depend on actual labor and material costs, actual Site conditions, productivity, competitive market conditions, final project scope, final project schedule, and other variable factors. As a result, the final project costs may vary from the estimates in this Response Plan.
Criterion 8 ‐ State Acceptance. This criterion considers the preferences or apparent concerns of the State, both technical and administrative, regarding the RAAs. This section will be completed after DTSC has had the opportunity to review and comment on the Draft Response Plan.
Criterion 9 ‐ Public Acceptance. This assessment will reflect the local community's preferences among the RAAs and concerns about the RAAs. This assessment will be completed after the public review and comment period is complete. Results of this assessment will be presented in the final Response Plan.
7.1 Remedial Action Alternatives – Soil
Three Remedial Action Alternatives were selected for further evaluation using the nine criteria presented above. The three Alternatives selected for further evaluation to address shallow soil impacts are:
• Alternative 1 ‐ No Further Action;
• Alternative 2 ‐ Containment through Surface Capping; and • Alternative 3 ‐ Excavation and Off-Site Disposal.
As described in DTSC’s Proven Technologies and Remedies Guidance – Remediation of Metals in Soil (DTSC, 2008), “containment by capping” and/or “excavation and offsite disposal” were the most frequently selected cleanup alternatives in DTSC’s evaluation of data for 188 sites where the primary contaminants were metals (primarily arsenic, chromium, lead, and mercury) . Site COCs include the metals arsenic and lead as well as PCB and PAHs. Therefore, DTSC’s proven technologies for remediation of metals are applicable to the evaluation and selection of remedial alternatives.
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7.1.1 Alternative 1 ‐ No Further Action
This alternative would require low or no cost and would be highly implementable from a technical feasibility perspective. The effectiveness of this alternative, however, would be poor; particularly with respect to long-term effectiveness, compliance with ARARs/TBCs, and overall protection of human health and the environment. This alternative would not achieve the RAOs and would not likely gain acceptance from the state and community.
7.1.2 Alternative 2 ‐ Containment through Surface Capping Containment of the contaminated soil would consist of capping the surface of the Site with an engineered cover, both on-Site and in the residential areas identified in the off‐Site investigation.
This alternative uses a geotextile membrane and engineered concrete cap over the Site to limit potential exposure of future Site occupants or construction workers through direct contact with the contaminants.
Impacted soil is generally present within the top 1 to 2 feet of soil across the majority of the Site.
Redevelopment of the property likely will require removal of several inches to 1 foot or more of surface soil to facilitate the import of base material and foundation construction on the Site. This shallow soil generally contains the higher concentrations of COCs in Site soil and would require special handling and mitigation using specially trained personnel . If a protective cap were to be installed now, it would require disturbance and soil disposal for property re-use. As such, the cost for containment through surface capping would encompass the cost to excavate and dispose of the shallow impacted soil, but would additionally include costs for the installation of the cap; monitoring and mitigation of off -site migration o f COCs during construction activities; ongoing monitoring of worker exposure during construction and resident exposure after construction; long- term operation and maintenance of the cap; and disturbance and remediation under the proposed redevelopment plan. In addition, residential properties impacted from the Site would have to agree to have portions of their unpaved yards capped.
Surface capping would necessitate a deed restriction on the Site, with requirements for additional activities before any future changes in Site use are approved.
The cost to implement Alternative 2 will essentially encompass the costs necessary to implement Alternative 3 (Excavation and Off -Site Disposal), but will add additional costs for construction monitoring, surface cap installation, residential exposure monitoring, long- term O&M of the surface cap, plus the unknown costs associated with the redevelopment of the property .
Additionally, the value of the Site will be reduced due to the potential for deed restrictions and additional remedial requirements . A reasonable range in the cost for this option is from 2 to 3 times the cost of Alternative 3.
Alternative 2 does not guarantee that the remaining soil will meet residential screening criteria and does not guarantee long- term effectiveness and permanence. The cost is prohibitive when compared to the cost of excavation and off-Site disposal. It is unlikely that the stakeholders or the community would choose this alternative over the option for Excavation and Off-Site Disposal.
7.1.3 Alternative 3 ‐ Excavation and Off-Site Disposal
The Excavation and Off-Site Disposal alternative would involve removal of approximately 28,200 cubic yards of soil from the Site, with an additional approximately 300 cubic yards removed from adjoining off‐Site residential properties. This alternative would require a program of targeted removal followed by a broad Site -wide excavation plan. Targeted removal would be conducted to remove areas identified with elevated PCB and lead concentrations that require GSI Job No.: 6239
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special handling . Site-wide excavation would be proposed to depths necessary to remove soil with COCs exceeding applicable RSLs. Soil removal would primarily be performed to a depth of approximately 1.0 feet bgs and up to 2.5 or 5.0 feet in areas where COCs have been detected at depth, or where confirmation sampling identifies COCs in remaining soil above remedial goals.
Excavation activities would include traditional and readily available excavation methods (i.e. excavator, backhoe, loader, etc.), and transportation of the impacted soil to approved off-Site facilities. No shoring or sloping of the overburden would be required for this task, but the waste would need to be segregated based on existing data and confirmation sampling. To remove and dispose of soil cost‐effectively, the soil would be segregated into RCRA and California hazardous and non- hazardous waste, as applicable and pretreated as necessary to meet land disposal restrictions.
This plan offers the most cost -effective solution to mitigate the current Site conditions. When completed, the impacted material would be removed from the Site so that the remaining soil meets residential screening criteria and the Site could be redeveloped without soil handling restrictions.
Permanent removal of the waste is expected to be acceptable to the Site owner, community, City of Riverside, USEPA, and DTSC.
Using each of the defined evaluation criteria, this alternative offers the most practical solution.
Remedial Alternative 3 has been selected as the best remedial alternative.
The estimated cost of completing this task can be broken down into parts with a range of uncertainty for each. Waste hauling and disposal costs will likely range from $50 to $250 per ton of soil. The net waste disposal will depend on the amount of total waste material generated and its ultimate destination.
Task Estimate
Health and Safety, Permitting, Mobilization, Staging, Water Meter, Health and Safety Coordination and Contracting, Project Management. $65,000 Fencing, Security, Traffic Management Plan $55,000
Storm Water Plan and Best Management Practices Plan $40,000 Limited Geotechnical Letter Report Requirement for Grading Permit $5,000 Demolition (Portland-cement and asphaltic concrete slabs, equipment pedestals) $150,000 Management and Stockpiling of Surface Debris $15,000
Excavation of Targeted Soil Removal Areas $15,000
Excavation and Confirmation Soil Sampling, and Stockpile Sampling $350,000 Soil Loading $65,000
Soil Disposal (assumes RCRA Haz, Cal-Haz, and Non-Haz waste streams) $2,750,000 Post Soil Sampling Human Health Risk Assessment $15,000 Clean up, Demobilization, and Reporting $30,000
Sub-Total $3,555,000
20% Contingency $711,000
Total $4,266,000
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7.2 Remedial Action Alternatives – Soil Vapor
Three Remedial Action Alternatives were selected for further evaluation using the nine criteria presented above. As described in Section 2.4, Iron Lofts has voluntarily elected to install and operate VIMS at future on- Site buildings and install and operate passive SSV at the existing historical building. As such, the baseline Remedial Action Alternative (or No Further Action) includes the installation and testing of vapor intrusion mitigation measures.
The four Alternatives selected for further evaluation to address potential vapor intrusion concerns are:
• Alternative A ‐ Vapor Intrusion Mitigation Measures at All on-Site Buildings; • Alternative B ‐ Excavation of Soil with VOCs in Soil Vapor and Off-Site Disposal; • Alternative C ‐ Soil Vapor Extraction (SVE); and
• Alternative D ‐ Vapor Intrusion Mitigation Measures at All on-Site Buildings with Institutional Controls.
7.2.1 Alternative A ‐ Vapor Intrusion Mitigation Measures at All on-Site Buildings This alternative includes the installation of VIMS at the new buildings and the installation of passive SSV at the existing historic building. Since Iron Lofts has elected to perform these mitigation measures regardless of the results of this FS evaluation, this alternative is considered to have low or no cost and would be highly implementable from a technical feasibility perspective.
The effectiveness of this alternative is uncertain, since the vapor intrusion mitigation measures would not be tested and may not be effective long- term if the VIMS and SSV systems are not maintained. This alternative would likely achieve the RAOs, but may not gain acceptance from the state and community. As such, this alternative is not retained.
7.2.2 Alternative B ‐ Excavation of Soil with VOCs in Soil Vapor and Off-Site Disposal Excavation in the area where PCE and TCE in soil vapor concentrations could pose a risk of vapor intrusion would require removing soil over an area of approximately 7 acres (~300,000 square feet) to a depth of greater than 30 feet below the pre-development grade (>330,000 cubic yards of soil just to 30 feet) . Excavation can be an effective technology where analytical results indicate a discrete impact that serves as the primary source to the presence of VOCs in soil vapor.
However, a source of PCE or TCE to soil vapor was not identified on the Site despite extensive soil vapor sampling, and it is possible that the low VOC concentrations are attributed to an off- Site release that is migrating in deeper soil vapor or groundwater to the Site. Excavation is not practical to address impacts to soil vapor due to 1) the considerable lateral extent and depth at which excavation could be required to remove impacted vapor entrapped in shallow soil, and 2) the negative impacts to the surrounding neighborhood. These negative impacts include increased traffic, dust generation, noise, and a much longer project schedule associated with this type of deeper excavation. An extended project schedule also would result in considerable financial impacts to the overall development project. Excavation of the soil with VOC-impacted soil vapor would not be effective as a stand-alone action in the long term if the source of VOCs in soil vapor is off-Site or the impacted soil vapor could not be removed, which may not be possible depending on the depth and lateral extent to which soil removal could be required. Given the impracticability and extreme cost to remove the source to the impacted soil vapor at depth, it is likely that there GSI Job No.: 6239
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would be residual impacted soil vapor at the excavation limits and backfilled soil following excavation would become impacted with VOCs again over time. As such, this alternative is not retained.
7.2.3 Alternative C ‐ Soil Vapor Extraction (SVE)
Active remediation technologies, such as SVE, would not be effective at the Site given the low and wide-spread concentrations of VOCs detected in soil vapor and lack of identified source to VOCs in soil vapor to 30 feet across the Site. Concentrations of VOCs in soil vapor at the Site in 2015, 2022, and 2023 are consistent and increase with depth with the highest concentrations across the Site at 30 feet below grade. Similar impacts have been identified at other properties in the area and these concentrations may be attributable to off-Site source(s). Significant effort was extended through soil and soil vapor sampling across the Site over several phases of investigation, including the 2015, 2022, and 2023 soil vapor sampling events. No source of VOCs has been identified to remove with SVE. As discussed in Section 2.2, groundwater is present beneath the Site at a depth of more than 100 feet. An SVE system would require numerous wells located across the 7 -acre Site and would have a high capital cost. Annual operation and maintenance are also expected to have a high cost. SVE will not be effective at remediating the distal end of an unidentified source and may require pulsed operation of the SVE for extended period of time as VOC concentrations continue to rebound. As such, this alternative is not retained.
7.2.4 Alternative D ‐ Vapor Intrusion Mitigation Measures at All on- Site Buildings with Institutional Controls
This alternative is the same as Alternative A with the inclusion of institutional controls, such as a land use covenant (LUC), to ensure the Site use does not change, building design remains the same, and VIMS and SSV are not modified. The LUC would encompass the entire Site, and the LUC prohibitions and requirements would be recorded with the Riverside County Recorder’s Office..
Two rounds of post-construction indoor air sampling will be conducted to provide additional lines of evidence that vapor intrusion is not occurring at the Site. Additional indoor air sampling will be performed, if necessary, based on the sampling results.
The effectiveness of this alternative is considered high. VIMS and passive SSV systems are highly effective, and the effectiveness for sites with low and wide-spread contamination of VOCs can be confirmed with post construction testing and maintained with an LUC and VIMS/SSV OM&M Plan. This alternative would achieve the RAOs and would likely gain acceptance from the state and community. As such, this alternative is retained.
The estimated cost of this alternative is approximately $20 per square foot of building foundation area.
7.3 Recommended Remedial Alternatives
Based on the discussion of each of the three RAA’s, Alternative 3 , Excavation and Off -Site Disposal, and Alternative D, Installation and Testing of Vapor Intrusion Mitigation Measures at All on-Site Buildings with Institutional Controls, have been chosen as the most reasonable alternatives for the Site.
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8.0 REMEDIAL ACTION IMPLEMENTATION
Implementation of Alternative 3 includes excavation and removal of the on‐Site impacted surficial soil to a depth of approximately 1.0 to 2.5 feet bgs, followed by soil confirmation sampling.
Impacted soil is present across approximately 5.5 acres of the Site. The expected volume of soil to be removed is approximately 20,000 cubic yards. Assuming 13 cubic yards of material per truckload, this would equate to approximately 1 ,500 one- way truck trips from the Project Site or approximately 43 truckloads leaving the Site per day over a period of 35 days . A similar volume of clean fill soil may be imported to the Site for grading.
A small portion of the total volume is highly impacted material that may be classified as RCRA waste, which requires special handling and is more costly to dispose. The remainder of the material may be classified as California hazardous waste or non‐hazardous waste. The objective of this program is to remove soil impacted with COCs above residential criteria and dispose of it cost‐effectively and safely. This will require a program of targeted removal followed by a broad Site-wide excavation plan. The off‐Site residential areas will be excavated during the targeted on‐Site excavation work and the impacted soil will be brought on‐Site to be temporarily staged prior to off-Site disposal.
8.1 Excavation Plan
The Excavation Plan calls for targeted removal in the vicinity of on-Site sample locations that contain impacted soil with either PCBs or lead concentrations that exceed or may exceed hazardous waste levels (Tables 4 and 5) . The plan is designed to address these higher concentration areas first, followed by Site-wide excavation of the remainder of Site with lower concentrations of COCs in soil.
Excavation from the targeted PCB and lead areas will be conducted using a backhoe excavator and the soil will be placed on and covered with plastic sheeting. The excavated areas will initially extend to approximately 1.0 foot. Confirmation soil samples will be obtained from the side walls and base of the lead target excavation areas to verify that the remaining in‐place soil is below the target concentrations, and based on confirmation data, the excavations will be expanded as necessary. The targeted PCB -impacted locations have undergone in- place pre- remedial confirmation sampling in accordance with TSCA guidelines.
Generated waste soil will be stockpiled on and covered with plastic sheeting or placed in roll -off bins for temporary staging pending off -Site disposal. Waste soil will be profiled for disposal in accordance with receiving facility requirements and procedures outlined in the USEPA Test Methods for Evaluating Soil Waste (SW-846), Chapter Nine (1986), and ASTM International Standard Guide for Sampling Waste Piles (Reapproved in 2006), as applicable. Waste profiling activities for excavated soils and will be documented and will consider prior Site sampling data.
8.1.1 Soil Impacted with PCBs exceeding 50 mg/kg
Six areas of PCB -impacted soil with reported concentrations that exceed 50 mg/kg will be excavated prior to commencement of the Site- wide excavation program, in accordance with TSCA regulations. This soil will be disposed of as RCRA waste. These excavations are defined based on the 2018 pre-remedial PCB delineation data summarized in Table 1 and are identified on Figures 4A and 4B. Soil will be excavated using a backhoe excavator and loaded directly into a truck for off-Site disposal.
Approximately 485 cubic yards of PCB-impacted soil above 50 mg/kg are anticipated for removal.
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8.1.2 Soil Impacted with RCRA Levels of Lead
Areas where soil is impacted by lead at RCRA-level concentrations will be excavated prior to the commencement of the Site- wide excavation program and may be treated on- Site by a DTSC - permitted transportable treatment unit (TTU) prior to off -Site transportation and disposal. These areas are defined based on the information included in Table 5 and shown on Figure 4C.
One area of RCRA‐level waste lead concentrations was identified at location S14 based on TCLP testing (>5 mg/L).
Fifteen sample locations are identified with California-hazardous waste level lead concentrations (<1,000 mg/kg total lead and > 5 mg/L soluble lead by WET) and several other samples have high lead or concentrations that meet the criteria for California hazardous waste based on TTLC test results (>1,000 mg/kg lead) and/or STLC guidelines based on WET results (5 mg/L).
Approximately 2,260 cubic yards of lead-impacted soil above RCRA Hazardous Waste levels are anticipated for removal. However, some of this volume of soil is co- located with PCB impacted soil identified in Section 8.1.1.
8.1.3 Lead, PCB, Arsenic and PAH exceeding Residential Soil RBSLs Based on historical data included in Appendix B.1, B.2, and B.3, COCs at the Site are present in the top approximately 1 foot of soil at the Site. Lead is present above RBSLs across a large portion of the Site and encompasses the areas where the other COCs are identified. As such, lead concentrations will primarily dictate the removal of soil. One exception is Area 8g, where the soil excavation area is dictated by elevated concentrations of arsenic in soil . Figure 5 identifies the overall excavation plan for the Site.
8.1.4 Residential Property Excavations
The off‐Site excavations on the residential properties will include targeted excavations intended to eliminate the impacted soil in these areas. This includes the immediate area around borings S1 and S8 (at 2981 Mission Inn), S9 and S12 (at 2968 6th Street), and S19, S20, S22, S23, and S24 (at 2981 6th Street) (Table 6, Figure 6A and Figure 6B). Off-Site excavation activities may require additional soil removal at the 2980 5th Street property in area(s) that could not be sampled but may have COC‐impacted soil based on available data collected at the RSIM Site.
The off ‐Site residential excavations will be completed to 1‐ foot bgs over the area identified in Figures 6A and 6 B. Approximately 300 cubic yards of soil is anticipated removal . Confirmation soil sampling will be used to ensure that the impacted soil had been adequately removed. If confirmation sampling suggests that soil with COCs above remedial goals has not been adequately removed, deeper targeted excavation will be conducted, and additional confirmation samples will be collected.
8.1.5 Indoor Air
Only low concentrations of PCE and TC E have been detected in soil vapor samples. Although the possibility of small on-Site releases of PCE and TCE cannot be ruled out, the soil vapor results are consistent with an off-Site source of PCE and TCE.
As part of the repurposing of the existing historic building for amenity space, existing crawl spaces will be vented passively, and the structure will be improved and built out, including installation of a modern HVAC system . The building renovation plans will be provided in a vapor intrusion mitigation plan prior to building occupancy or addendum to the Response Plan.
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8.2 Permitting
It is expected that the following permits may be required for excavation operations:
• A grading permit from the City; and
• An Air District Rule 1466 permit may be required due to the concentrations of COCs in the soil.
The excavation and soil handling will be conducted by a qualified, HAZWOPER -trained, contractor using conventional earthwork equipment . The contractor will prepare a Site- specific HASP, which will address identification of hazards, hazard mitigation, safe work practices and emergency response procedures for the project.
The following sections discuss permitting and compliance requirements to implement the remedial activities. The selected remedial contractor will be responsible for compliance monitoring and meeting the requirements described below.
8.2.1 SCAQMD Rules 401, 403, and 1466
To control fugitive dust emissions from earth- moving activities at sites containing soil with applicable toxic air contaminants, which include Site COCs, and to be in compliance with requirements contained in SCAQMD Rules 403 and 1466, several measures will be performed at the Site during the remedial activities, including:
• Notification to SCAQMD of planned earth-moving activities in compliance with Rule 1466; • Documentation of Rule 1466 procedures implemented using SCAQMD Rule 1466 record keeping logs.
• Application of water to control dust generation at the working face and other points of dust/odor generation;
• Stockpile control – covers, wetting;
• Cease work conditions – wind speed, odor, or particulate monitoring thresholds; • Truck loading and covering procedures; and
• Housekeeping (street cleaning as necessary).
To further control dust emissions and to comply with SCAQMD Rules 401, 403, and 1466 requirements, rumble strips consisting of metal plates with raised rails may be utilized to remove bulk material from tires and vehicle undercarriages, if necessary. The r umble strips would be placed at the egress point where the Site meets a paved public road. Rumble strips are only anticipated if clean import soils are required to grade the area to facilitate design specification and drainage for paving. Contractor bid selection documents will require that contractors demonstrate their ability to implement remedial activities in compliance with applicable SCAQMD regulations, including Rule 1466.
8.2.2 Surface Runoff Control
Surface runoff and storm water will be prevented from leaving the Site by implementing the Storm Water Pollution Prevention Plan (SWPPP). The SWPPP will provide a plan for controlling potential run off during excavation activities. Best management practices (BMPs) will be implemented as outlined in the SWPPP during Response Plan activities.
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8.2.3 Waste Transportation and Disposal Documentation, and Transporter Requirements Regulations regarding documentation necessary for the transportation and disposal of hazardous waste are included under 40 CFR Part 262 and transporter requirements are included under 40 CFR Part 263.
8.3 Site Preparation and Utility Clearance
Prior to remediation activities, the selected contractors will conduct initial mobilization activities.
These activities include:
• Identification of overhead and subgrade utilities that may be affected by the proposed remedy;
• Underground Service Alert /Dig Alert notification to identify underground utility lines that may conflict with the proposed paving activities.
• Dig Alert will mark each utility with the proper identification and coloring. A geophysical survey contractor may be used to locate utilities at the Site. • Identification of access/egress for staff, vehicles and equipment, and • Placement of temporary construction signage along roadways utilized for access/egress to and from the Site.
8.4 Field Variances
As conditions in the field can vary, it may be necessary to implement minor modifications to the recommended procedures presented in this Response Plan. Field personnel will notify the property owner, USEPA, and DTSC when deviations from the Response Plan are necessary, and a verbal or written concurrence, as appropriate, will be obtained before implementing the modification, if substantive. If encountered field conditions dictate the need for a significant modification to the procedures outlined in this Response Plan, such as the discovery of an unexpected area of contamination requiring remedial action or a major unidentified utility, the USEPA and DTSC will be notified for consultation and concurrence with any project modifications before proceeding. The property owner and DTSC will respond to all requests for review and/or concurrence in a timely manner to minimize potential impacts to the project schedule.
Modifications to the approved Response Plan will be documented in the field variances section of the Response C ompletion Report (RCR) that will be prepared at the conclusion of remedial activities.
8.5 Waste Profiling and Classification
Soil waste that is not immediately loaded and removed from the Site will be stockpiled, sampled and analyzed for proper waste profiling, transportation and off-Site disposal.
GSI will collect representative waste characterization samples from each soil stockpile in general accordance with Chapter 9 of USEPA publication SW -846, Test Methods for Evaluation Solid Waste, Physical/Chemical Methods (SW -846) and prior to waste disposal under manifest. The waste characterization samples will be submitted to a State- certified laboratory and will be analyzed for the following constituents, at a minimum, or additional constituents if required by a receiving facility:
• Metals using USEPA Method 6010/7471;
• PCBs using USEPA Method 8082;
• PAHs using USEPA Method 8270 or 8310;
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• VOCs using USEPA Method 8260B; and
• Petroleum hydrocarbons using USEPA Method 8015.
The excavated waste soil will be managed and disposed off -Site in compliance with applicable requirements. Selection of the appropriate waste disposal facility will be based on results of waste characterization, receiving facility acceptance criteria, and the availability for the facilities identified in the Transportation Plan to accept such waste at the time of disposal.
8.6 Investigation Derived Waste
The types of investigation derived waste (IDW) that may be generated during field activities include but are not limited to disposable personal protective equipment (nitrile gloves and booties), rags, and equipment decontamination wastewater. These types of waste shall be contained and disposed of in accordance with 40 C.F.R. § 761.61(a)(5)(v).
Labels will be placed on drums or other containers storing PCB -related and other IDW that are pending laboratory analysis for disposal. Accumulation start dates will be identified on all drums or other containers used to hold IDW. Labels will be replaced when worn or illegible. Generation of hazardous IDW is not anticipated, however, if hazardous IDW is generated, it will be separated from non-hazardous IDW, if possible, to minimize the volume of hazardous IDW that must be properly managed.
8.7 Health and Safety
Contractor will develop their own Site‐specific HASP for work conducted at the Site as required pursuant to the regulations in 29 CFR Part 1910.120 and California Code of Regulations (CCR), Title 8, Section 5192. The HASP will be prepared for the work described in this Response Plan and will include the details regarding physical and chemical hazards that could be encountered at the Site. The HASP will address the safety and health hazards of each activity in the removal design, including the requirements and procedures for worker protection. The implementation of the HASP is the responsibility of the designated Site Health and Safety Officer . The HASP will also include a map showing directions between the Site and the local hospital or emergency center.
9.0 CONFIRMATION SAMPLING
Soil confirmation sampling will be conducted at the Site.
9.1 Soil Sampling
Pre-excavation in-place confirmation samples were collected for the >50 mg/kg PCB -impacted areas. As discussed between GSI, USEPA, and DTSC during sampling activities, in accordance with 40 CFR 761.61(a)(5)(i)(B)(2), bulk PCB remediation waste that exceeds 50 mg/kg total PCBs shall be disposed of at a hazardous waste landfill permitted by EPA under section 3004 of RCRA or a State authorized disposal facility under section 3006 of RCRA . For soils containing PCBs that are detected above the action level but below 50 mg/kg, the bulk remediation waste may be disposed of in accordance with 40 CFR 761.61(a)(5)(v)(A), which includes a municipal solid waste landfill that is permitted, licensed, or registered by a State, among other options.
PCB-impacted areas that exceed 50 mg/kg have been delineated in- place with one exception; the area to the south of sample location (KK26) where concentrations of PCBs exceed 50 mg/kg.
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Additional confirmation sampling was postponed at this location to complete the original RAP.
DTSC and USEPA concurred that confirmation soil sampling could be conducted after targeted PCB removal in the area south of KK26 to document that remedial excavation goals for PCBs are met during the planned excavation event. 8 Note that targeted lead excavation areas were not delineated “in-place” and will have confirmation sampling performed to document achievement of the remedial goal for lead.
Confirmation soil samples will be collected from the base of the excavation in a grid pattern with samples collected every 60 feet. The sample locations where COCs have historically exceeded RSLs and their closest associated confirmation sample node are included in Table 7. Sidewall samples will be collected along the perimeter of the Site excavation, co-located near the planned bottom sample. In addition, four sidewall samples will be collected from deeper excavations.
Excavation will be performed on the off-Site properties to remove surface soil with COCs above remedial goals as identified in Table 3. Progress and confirmation soil samples will be collected, as shown on Figure 6A and 6B, to confirm the lateral and vertical extent of soil with COCs above remedial goals is removed. Additional sampling will be performed on the 2981 Mission Inn Avenue property adjacent to an on-Site soil removal area to confirm PCB-impacted soil on-Site along the property boundary has been r emoved. Off-Site residential excavations will have confirmation samples collected approximately every 10 feet along bottoms and/or sidewalls to confirm remedial objectives are met for the residential properties.
All confirmation sampling will be documented in the Response Completion Report ( RCR). The results of confirmation sampling will be compared to the remedial goals presented in Table 3. The locations of the proposed confirmation soil samples for on- Site excavations are shown on Figure 7. The proposed confirmation samples for off ‐Site excavations are shown on Figures 6 A and 6B.
Confirmation soil samples will be collected using manual or direct -push sampling methods in appropriate sampling containers for the requested analyses . Confirmation samples will be analyzed for Title 22 (CAM -17) metals, PCBs, and PAHs across the Site and for TPH in TPH removal areas. Any sampling of PCBs, whether for purposes of confirmation sampling or waste profiling, shall include the Soxhlet Extraction Method (EPA Method 3541 [SW-846]).
In areas where confirmation sampling suggests that soil with COCs above remedial goals has not been adequately removed, deeper targeted excavation will be conducted, and additional confirmation samples will be collected.9
9.2 Indoor Air Sampling
Two rounds of post-construction indoor air sampling will be conducted to provide additional lines of evidence that vapor intrusion is not occurring at the Site. Additional indoor air sampling will be performed, if necessary, based on the sampling results.
8 Conference call between GSI, RSIM, USEPA, and DTSC representatives and e-mail from USEPA dated 8 February 2019.
9 Step-out samples will be identified as in the following example: If analysis of confirmation sample "9-6" indicates that lead is present above residential screening criteria, step out samples may be collected 10 feet in each direction into (continued) the north quadrant, south quadrant, east quadrant, and west quadrant . As such, these samples would be identified as "9-6N -10", "9 -6S-10", "9-6E -10", and "9- 6W-10". The appropriate step-out distance from the original sample will be determined in the field and approved by USEPA and DTSC.
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9.3 Human Health Risk Assessment
Following completion of confirmation soil sampling, GSI will prepare an HHRA and include in the Response Action Completion Report to confirm attainment of remedial objectives and evaluate whether additional post -Response Plan implementation mitigation measures are necessary to support the proposed future residential redevelopment of the Site.
Two rounds of post-construction indoor air sampling will be conducted to provide additional lines of evidence that vapor intrusion is not occurring at the Site. Additional indoor air sampling will be performed, if necessary, based on the sampling results.
10.0 PUBLIC PARTICIPATION AND CEQA DOCUMENTATION
An administrative record for the Site is maintained by the State Water Resources Control Board (SWRCB) and DTSC and is publicly accessible via SWRCB’s Geotracker website and DTSC’s Envirostor website.10,11 The administrative record includes Site history information, environmental data, investigation and remediation reports, and regulatory orders and correspondence for public access, review and/or comment. The Response Plan and all related technical documents will be placed on the DTSC Envirostor website.
A Community Survey (in both English and Spanish) was mailed to local residents within 0.25-mile of the Site, and stakeholders on December 11, 2022 . The Community Survey noted that a Community Update would be distributed in the future to provide a summary of proposed activities and an opportunity to review and comment on the draft Response Plan.
The Community Update will be distributed with 30 days public notice to interested local residents within 0.25-mile of the Site, and stakeholders in a factsheet format of the proposed response plan, in English and Spanish. Once the 30- day public comment period ends, DTSC will respond in writing to all public comments in a Response to Comments (RTC) document that will be mailed to all individuals who submitted a comment . Further, DTSC staff will be available to respond to community phone calls and email communication as related to the RTC . If a public meeting is deemed necessary, it will be coordinated with DTSC.
The Response Plan will be revised, as necessary, to address comments received. If significant changes to the Response Plan are required, it will be revised and be resubmitted to DTSC for public review and comment. If significant changes are not required to the Response Plan, it will be modified, as necessary, and DTSC will approve the modified Response Plan for implementation.
In compliance with the California Environmental Quality Act (CEQA), DTSC is currently reviewing an Initial Study (IS) in support of a Mitigated Negative Declaration (MND). 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 possible. The IS and MND documents will evaluate if there will be any significant environmental impacts that may result from this project. The draft IS and MND documents will be made available for public review at a later date.
10 https://geotracker.waterboards.ca.gov/profile_report?global_id=T10000005690 11 https://www.envirostor.dtsc.ca.gov/public/profile_report?global_id=60002350 GSI Job No.: 6239
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11.0 PROJECT SCHEDULE
The following is a general proposed schedule for implementation of this Response Plan following DTSC approval of the remedial alternative proposed. The indicated number of days are presumed to follow completion of the preceding task; however, tasks that may occur concurrently may be performed simultaneously as appropriate. The schedule begins upon DTSC approval of a remedial alternative, and at the close of the required public comment period.
Exhibit 12-1. Project Schedule
Date to Complete* Task
7/15/24-10/23/24
Response Plan Approval; Public Participation (notice preparation, comment period, and review of comments); Public Notice and Fact Sheet; Contractor Solicitation, Bidding, and Selection; Response Plan Implementation Planning; Permitting
10/24/24-12/18/24 Site Preparation, Mobilization, and Implementation of Response Plan 12/19/24-2/19/24 Compile Response Completion Report (RCR) for submittal to DTSC. *The implementation schedule is contingent upon the time necessary to procure necessary permits.
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12.0 REFERENCES
AMEC Foster Wheeler (AMEC), 2015, Additional Phase II Environmental Site Assessment Report, December 9.
Ami Adini & Associates (AA&A), 2011, Phase II Environmental Site Assessment. August 8.
Agency for Toxic Substances and Disease Registry (ATSDR), 1997, Toxicological Profile for Chloroform, United States Department of Health and Human Services, September.
California Environmental Protection Agency, 2015, Advisory – Active Soil Gas Investigations, July
DTSC, 2008. Proven Technologies and Remedies Guidance, Appendix C -2. California Environmental Protection Agency. August 29.
DTSC, 2009. Advisory – Use of PAH Studies in Manufactured Gas Plant Site Cleanup Process .
California Environmental Protection Agency July 1.
DTSC, 2011. Guidance for the Evaluation and Mitigation of Subsurface Vapor Intrusion to Indoor Air (Vapor Intrusion Guidance). California Environmental Protection Agency. October.
DTSC, 2020. Human Health Risk Assessment (HHRA) Note Number 11, Southern California Ambient Arsenic Screening Level, December 28.
DTSC, 2022. Human Health Risk Assessment (HHRA) Note 3, HHRA Note 3, DTSC- modified Screening Levels (DTSC-SLs). California Environmental Protection Agency. May.
Doucette, WJ; AJ Hall, and KA Gorder, 2009. Emissions of 1,2- Dichloroethane from Holiday Decorations as a Source of Indoor Air Contamination, Ground Water Monitoring & Remediation, Winter 2010: 30 (1): 65-71
Geomatrix Consultants, Inc. (Geomatrix), 2005. Phase I Environmental Site Assessment, Marketplace Brownfields Site, City of Riverside Redevelopment Agency, Riverside, California, September 14.
GSI Environmental, 2022, Site Assessment and Report of Findings, Former Riverside Scrap Iron and Metal Property, 2993 6th Street, Riverside, California, August 3.
Hillmann, 2017a, Off-Site Preliminary Environmental Assessment, February 27.
Hillmann, 2017b, Revised Technical Memorandum Workplan for Delineation of RCRA Level PCB- Impacted Soil, October.
Hillman, 2021, Phase I Environmental Site Assessment, 2992, 2008 5 th Street, 2993 6th Street, 3596 Commerce, and 2993 Mission Inn Avenue, Riverside, California, September 21.
Ninyo & Moore, 2020, Revised Limited Phase II Environmental Site Assessment, 10 APNs Adjacent to the Riverside Downtown Metrolink Station, Riverside, California, March 30.
San Francisco Bay Regional Water Quality Control Board (SFRWQCB) . 2019. Environmental Screening Levels (ESLs). January.
GSI Job No.: 6239
Former Riverside Scrap Iron & Metal Property Response Plan TABLES
Table 1. Polychlorinated Biphenyls (PCBs) in Soil
Table 2. Applicable or Relevant and Appropriate Requirements (ARARs) and To-be- considered Criteria (TBCs)
Table 3. Remedial Goals for Chemicals of Concern (COCs) in Soil Table 4. Targeted Polychlorinated Biphenyls (PCB) Excavations Table 5. Targeted Lead Excavations
Table 6. Off-Site Excavations
Table 7. Constituents Exceeding Residential Screening Levels GSI Job No. 6239
PCB-1016 PCB-1221 PCB-1232 PCB-1242 PCB-1248 PCB-1254 PCB-1260 Total PCBs
Area 8A
A8a-SB1 8a SB1 NA 1/27/2011 1 <0.05 <0.1 <0.05 <0.05 <0.05 0.199 <0.05 0.199 A8a-SB2 8a SB2 NA 1/27/2011 1 <0.05 <0.1 <0.05 <0.05 <0.05 0.79 <0.05 0.79 A8a-SB3 8a SB3 NA 1/27/2011 1 <0.05 <0.1 <0.05 <0.05 2.96 2.66 <0.05 5.62 A8a-SB4 8a SB4 NA 1/27/2011 1 <0.05 <0.1 <0.05 <0.05 <0.05 <0.05 <0.05 All ND A8a-SB5 8a SB5 NA 1/27/2011 1 <0.05 <0.1 <0.05 <0.05 8.15 4.6 <0.05 12.75 A8a-SB6 8a SB6 NA 1/27/2011 1 <0.05 <0.1 <0.05 <0.05 26.8 5.95 <0.05 32.75 NS9 8a NS9 NA 8/11/2015 2.5 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 All ND S12 8a S12 NA 8/12/2015 0.25 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 All ND S9 8a S9 NA 8/12/2015 0.25 <0.02UJ <0.02UJ <0.02UJ .120J <0.02UJ 0.280J 0.130J 0.53 S11 8a S11 NA 8/13/2015 0.25 <0.2 <0.2 <0.2 1.6 <0.2 1.4J 0.43 3.43 S11 8a S11 NA 8/13/2015 1 <0.2 <0.2 <0.2 <0.2 <0.2 <0.2 <0.2 All ND S11 8a S11 NA 8/13/2015 2.5 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 All ND S8 8a S8 NA 8/13/2015 2.5 <0.2 <0.2 <0.2 <0.2 <0.2 <0.2 <0.2 All ND S13 8a S13 NA 8/14/2015 0.25 <0.02 <0.02 <0.02 4.2 <0.02 1.6 0.3 6.1 NS7 8a NS7 NA 8/21/2015 2.5 <0.02 <0.02 <0.02 0.055 <0.02 0.11 0.058 0.223 NS8 8a NS8 NA 8/21/2015 0.25 <0.02UJ <0.02UJ <0.02UJ 2.2J <0.02UJ .350J 0.110J 2.66 NS8 8a NS8 NA 8/21/2015 2.5 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 All ND Area 8B
A8b-SB2 8b SB2 NA 1/28/2011 1 <0.05 <0.1 <0.05 <0.05 <0.05 <0.05 <0.05 All ND A8b-SB3 8b SB3 NA 1/28/2011 1 <0.05 <0.1 <0.05 <0.05 0.18 0.274 <0.05 0.454 A8b-SB4 8b SB4 NA 1/28/2011 1 <0.05 <0.1 <0.05 <0.05 <0.05 0.903 <0.05 0.903 ES2 8b ES2 NA 8/14/2015 0.25 <0.02UJ <0.02UJ <0.02UJ <0.02UJ <0.02UJ <0.02UJ 22J 22 ES2 8b ES2 NA 8/14/2015 2.5 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 All ND S16 8b S16 NA 8/14/2015 2.5 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 All ND A8b-SB1 8b SB1 Initial >50 Sample 1/27/2011 1 <0.05 <0.1 <0.05 <0.05 369 125 <0.05 494 A8b-SB1X-2.5 8b SB1 X 1/23/2018 2.5 <0.055 <0.055 <0.055 <0.055 <0.055 <0.055 <0.055 All ND A8b-SB1A-1 8b SB1 A 1/23/2018 1 <0.054 <0.054 <0.054 <0.054 <0.054 <0.054 <0.054 All ND A8b-SB1A-2.5 8b SB1 A 1/23/2018 2.5 <0.056 <0.056 <0.056 <0.056 <0.056 <0.056 <0.056 All ND A8b-SB1B-1 8b SB1 B 1/23/2018 1 <0.054 0.25 <0.054 <0.054 <0.054 <0.054 <0.054 0.25 A8b-SB1B-2.5 8b SB1 B 1/23/2018 2.5 <0.055 <0.055 <0.055 <0.055 <0.055 <0.055 <0.055 All ND A8b-SB1C-1 8b SB1 C 1/23/2018 1 <0.055 <0.055 <0.055 <0.055 0.26 0.14 <0.055 0.4 A8b-SB1C-2.5 8b SB1 C 1/23/2018 2.5 <0.055 <0.055 <0.055 <0.055 <0.055 <0.055 <0.055 All ND A8b-SB1D-1 8b SB1 D 1/23/2018 1 <0.054 <0.054 <0.054 <0.054 <0.054 <0.054 <0.054 All ND A8b-SB1D-2.5 8b SB1 D 1/23/2018 2.5 <0.054 <0.054 <0.054 <0.054 <0.054 <0.054 <0.054 All ND depth
(feet bgs)
EPA Method 8082 (mg/kg)
TABLE 1. POLYCHLORINATED BIPHENYLS (PCBs) in SOIL
Former Riverside Scrap Iron & Metal Property
Riverside, California
Sample/
Boring
ID
Area Sample
Location
2018 Investigation
Step-Out Sample
Designation or
Information
Sample Date
Remedial Action Plan
GSI Job No. 6239
PCB-1016 PCB-1221 PCB-1232 PCB-1242 PCB-1248 PCB-1254 PCB-1260 Total PCBs
depth
(feet bgs)
EPA Method 8082 (mg/kg)
TABLE 1. POLYCHLORINATED BIPHENYLS (PCBs) in SOIL
Former Riverside Scrap Iron & Metal Property
Riverside, California
Sample/
Boring
ID
Area Sample
Location
2018 Investigation
Step-Out Sample
Designation or
Information
Sample Date
Remedial Action Plan
Area 8C
A8c-SB1 8c SB1 NA 1/27/2011 1 <0.05 <0.1 <0.05 <0.05 <0.05 <0.05 <0.05 All ND A8c-SB2 8c SB2 NA 1/27/2011 1 <0.05 <0.1 <0.05 <0.05 10.4 1.4 <0.05 11.8 A8c-SB3 8c SB3 NA 1/27/2011 1 <0.05 <0.1 <0.05 <0.05 24.3 2.67 <0.05 26.97 A8c-SB4 8c SB4 NA 1/27/2011 1 <0.05 <0.1 <0.05 <0.05 <0.05 <0.05 <0.05 All ND NS14 8c NS14 NA 8/14/2015 2.5 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 All ND NS15 8c NS15 NA 8/14/2015 0.25 <0.02 <0.02 <0.02 1.5 <0.02 1.6 0.29 3.39 NS15 8c NS15 NA 8/14/2015 2.5 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 All ND NS10A 8c NS10A NA 8/21/2015 0.25 <0.02UJ <0.02UJ <0.02UJ .110J <0.02UJ .200J 0.100J 0.41 Area 8D
A8d-SB1 8d SB1 NA 1/26/2011 1 <0.05 <0.1 <0.05 <0.05 <0.05 <0.05 <0.05 All ND A8d-SB2 8d SB2 NA 1/26/2011 1 <0.05 <0.1 <0.05 <0.05 <0.05 5.84 <0.05 5.84 A8d-SB3 8d SB3 NA 1/26/2011 1 <0.05 <0.1 <0.05 <0.05 <0.05 0.903 <0.05 0.903 A8d-SB4 8d SB4 NA 1/26/2011 1 <0.05 <0.1 <0.05 <0.05 <0.05 0.372 <0.05 0.372 NS25 8d NS25 NA 8/18/2015 0.25 <0.02UJ <0.02UJ <0.02UJ <0.02UJ <0.02UJ 1.3J 0.140J 1.44 NS25 8d NS25 NA 8/18/2015 1 <0.02 <0.02 <0.02 <0.02 <0.02 0.042 <0.02 0.042 NS26 8d NS26 NA 8/12/2015 0.25 <0.02UJ <0.02UJ <0.02UJ 0.32J <0.02UJ 12J 1.600J 13.92 NS26 8d NS26 NA 8/12/2015 1 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 All ND NS27 8d NS27 NA 8/12/2015 0.25 <0.02 <0.02 <0.02 <0.02 <0.02 0.012 0.097 0.109 NS28 8d NS28 NA 8/12/2015 0.25 <0.02UJ <0.02UJ <0.02UJ 2.0J <0.02UJ 0.86J .180J 3.04 NS28 8d NS28 NA 8/12/2015 1 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 All ND NS29 8d NS29 NA 8/12/2015 0.25 <0.02UJ <0.02UJ <0.02UJ 0.058J <0.02UJ 0.11J 0.089J 0.257 NS30 8d NS30 NA 8/21/2015 0.25 <0.02UJ <0.02UJ <0.02UJ <0.02UJ <0.02UJ 0.044J 0.045J 0.089 S4 8d S4 NA 8/18/2015 0.25 <0.02 <0.02 <0.02 0.14 <0.02 0.94 0.071 1.151 S4 8d S4 NA 8/18/2015 2.5 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 All ND S5 8d S5 NA 8/12/2015 0.25 <0.02 <0.02 <0.02 <0.02 <0.02 0.17 0.093 0.263 S5 8d S5 NA 8/12/2015 2.5 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 All ND NS2 8d NS2 NA 8/18/2015 0.25 <0.02 <0.02 <0.02 8.6 <0.02 28 2.3J 38.9 NS2 8d NS2 Initial >50 Sample 8/18/2015 1 <0.02UJ <0.02UJ <0.02UJ 62J <0.02UJ 290J 34J 386 NS2 8d NS2 Initial >50 Sample 8/18/2015 2.5 <0.02 <0.02 <0.02 <0.02 <0.02 0.023 <0.02 0.023 NS2A-1 8d NS2 A 1/23/2018 1 <55 <55 <55 <55 500 670 <55 1170 NS2A-2.5 8d NS2 A 1/23/2018 2.5 <0.054 <0.054 <0.054 <0.054 0.21 0.41 <0.054 0.62 NS2B-1 8d NS2 B 1/23/2018 1 <53 <53 <53 <53 350 520 <53 870 NS2B-2.5 8d NS2 B 1/23/2018 2.5 <0.27 <0.27 <0.27 <0.27 1.3 1.8 <0.27 3.1 NS2C-1 8d NS2 C 1/23/2018 1 <5.7 <5.7 <5.7 <5.7 39 71 <5.7 110 NS2C-2.5 8d NS2 C 1/23/2018 2.5 <0.28 <0.28 <0.28 <0.28 0.65 1.5 <0.28 2.15 NS2D-1 8d NS2 D 1/23/2018 1 <55 <55 <55 <55 150 280 <55 430 NS2D-2.5 8d NS2 D 1/23/2018 2.5 <0.055 <0.055 <0.055 <0.055 0.12 0.2 <0.055 0.32 NS2E-0.5 8d NS2 E 5/18/2018 0.5 <5.4 <5.4 <5.4 <5.4 17 23 <5.4 40 NS2E-1 8d NS2 E 5/18/2018 1 <0.55 <0.55 <0.55 <0.55 1.1 1.8 <0.55 2.9 NS2F-0.5 8d NS2 F 5/18/2018 0.5 <0.053 <0.053 <0.053 <0.053 0.2 0.11 <0.053 0.31 NS2F-1 8d NS2 F 5/18/2018 1 <5.6 <5.6 <5.6 <5.6 11 13 <5.6 24 NS2G-0.5 8d NS2 G 5/18/2018 0.5 <0.55 <0.55 <0.55 <0.55 4.3 8.3 <0.55 12.6 GSI Job No. 6239
PCB-1016 PCB-1221 PCB-1232 PCB-1242 PCB-1248 PCB-1254 PCB-1260 Total PCBs
depth
(feet bgs)
EPA Method 8082 (mg/kg)
TABLE 1. POLYCHLORINATED BIPHENYLS (PCBs) in SOIL
Former Riverside Scrap Iron & Metal Property
Riverside, California
Sample/
Boring
ID
Area Sample
Location
2018 Investigation
Step-Out Sample
Designation or
Information
Sample Date
Remedial Action Plan
NS2G-1 8d NS2 G 5/18/2018 1 <5.3 <5.3 <5.3 <5.3 13 28 <5.3 41 NS2H-0.5 8d NS2 H 5/18/2018 0.5 <5.4 <5.4 <5.4 <5.4 210 330 <5.4 540 NS2H-1 8d NS2 H 5/18/2018 1 <2.7 <2.7 <2.7 <2.7 7.3 14 <2.7 21.3 NS2I-0.5 8d NS2 I 5/18/2018 0.5 <0.054 <0.054 <0.054 <0.054 <0.054 <0.054 <0.054 All ND NS2I-1 8d NS2 I 5/18/2018 1 <0.51 <0.51 <0.51 <0.51 0.78 2 <0.51 2.78 NS2K-0.5 8d NS2 K 5/18/2018 0.5 <0.051 <0.051 <0.051 <0.051 0.21 0.12 <0.051 0.33 NS2K-1 8d NS2 K 5/18/2018 1 <5.3 <5.3 <5.3 <5.3 43 67 <5.3 110 NS2KK-2.5 8d NS2 KK 8/3/2018 2.5 <0.053 <0.053 <0.053 <0.053 0.082 0.16 <0.053 0.242 NS2KK1-1 8d NS2 KK1 8/3/2018 1 <2.6 <2.6 <2.6 <2.6 6.8 29 <2.6 35.8 NS2L-0.5 8d NS2 L 5/18/2018 0.5 <0.11 <0.11 <0.11 <0.11 0.49 0.26 <0.11 0.75 NS2L-1 8d NS2 L 5/18/2018 1 <0.54 <0.54 <0.54 <0.54 75 280 <0.54 355 NS2LL-2.5 8d NS2 LL 8/3/2018 2.5 <0.26 <0.26 <0.26 <0.26 <0.26 1.2 <0.26 1.2 NS2M-0.5 8d NS2 M 5/18/2018 0.5 <5.4 <5.4 <5.4 <5.4 98 86 <5.4 184 NS2M-1 8d NS2 M 5/18/2018 1 <0.57 <0.57 <0.57 <0.57 1.4 3 <0.57 4.4 NS2N-0.5 8d NS2 N 5/18/2018 0.5 <0.5 <0.5 <0.5 <0.5 3.2 <0.5 <0.5 3.2 NS2N-1 8d NS2 N 5/18/2018 1 <54 <54 <54 <54 410 670 <54 1080 NS2NN1-1 8d NS2 NN 8/3/2018 1 <1.1 <1.1 <1.1 <1.1 5.3 12 <1.1 17.3 NS2NN-2.5 8d NS2 NN 8/3/2018 2.5 <5.3 <5.3 <5.3 <5.3 14 30 <5.3 44 NS2O-0.5 8d NS2 O 5/18/2018 0.5 <0.51 <0.51 <0.51 <0.51 3.9 <0.51 <0.51 3.9 NS2O-1 8d NS2 O 5/18/2018 1 <5.2 <5.2 <5.2 <5.2 21 43 <5.2 64 NS2OO1-1 8d NS2 OO 8/3/2018 1 <0.53 <0.53 <0.53 <0.53 4.5 4 <0.53 8.5 NS2OO-2.5 8d NS2 OO 8/3/2018 2.5 <0.054 <0.054 <0.054 <0.054 <0.054 0.065 <0.054 0.065 NS2P-0.5 8d NS2 P 5/18/2018 0.5 <0.054 <0.054 <0.054 <0.054 0.19 <0.054 <0.054 0.19 NS2P-1 8d NS2 P 5/18/2018 1 <5.4 <5.4 <5.4 <5.4 44 25 <5.4 69 NS2PP1-1 8d NS2 PP 8/3/2018 1 <5.3 <5.3 <5.3 <5.3 88 53 <5.3 141 NS2PP-2.5 8d NS2 PP 8/3/2018 2.5 <0.054 <0.054 <0.054 <0.054 0.11 0.13 <0.054 0.24 NS2PP1-2.5 8d NS2 PP1 8/3/2018 2.5 <0.055 <0.055 <0.055 <0.055 <0.055 <0.055 <0.055 All ND NS2PP2-1 8d NS2 PP2 8/3/2018 1 <0.52 <0.52 <0.52 <0.52 3.4 3.5 <0.52 6.9 NS2PP3-1.0 8d NS2 PP3 9/27/2018 1 <5.2 <5.2 <5.2 <5.2 42 37 <5.2 79 NS2PP3-2.5 8d NS2 PP3 9/27/2018 2.5 <0.054 <0.054 <0.054 <0.054 <0.054 <0.054 <0.054 All ND NS2PP4-1.0 8d NS2 PP4 9/27/2018 1 <0.52 <0.52 <0.52 <0.52 1.9 4.3 <0.52 6.2 NS2PP5-1.0 8d NS2 PP5 9/27/2018 1 <55 <55 <55 <55 630 760 <55 1390 NS2PP5-2.5 8d NS2 PP5 9/27/2018 2.5 <0.054 <0.054 <0.054 <0.054 <0.054 1.2 <0.054 1.2 NS2PP6-1.0 8d NS2 PP6 9/27/2018 1 <5.4 <5.4 <5.4 <5.4 310 600 <5.4 910 NS2PP6-2.5 8d NS2 PP6 9/27/2018 2.5 <0.054 <0.054 <0.054 <0.054 0.19 0.25 <0.054 0.44 NS2PP7-1.0 8d NS2 PP7 9/27/2018 1 <0.053 <0.053 <0.053 <0.053 <0.053 0.12 <0.053 0.12 NS2PP7-2.5 8d NS2 PP7 9/27/2018 2.5 <0.054 <0.054 <0.054 <0.054 <0.054 <0.054 <0.054 All ND NS2PP0-1 8d NS2 PP9 9/27/2018 1 <0.052 <0.052 <0.052 <0.052 0.61 1 <0.052 1.61 NS2PP9-2.5 8d NS2 PP9 9/27/2018 2.5 <0.053 <0.053 <0.053 <0.053 <0.053 <0.053 <0.053 All ND NS2PP10-1.0 8d NS2 PP10 9/27/2018 1 <0.053 <0.053 <0.053 <0.053 11 19 <0.053 30 NS2PP10-2.5 8d NS2 PP10 9/27/2018 2.5 <0.052 <0.052 <0.052 <0.052 0.13 0.1 <0.052 0.23 NS2Q-0.5 8d NS2 Q 5/18/2018 0.5 <0.052 <0.052 <0.052 <0.052 <0.052 <0.052 <0.052 All ND NS2Q-1 8d NS2 Q 5/18/2018 1 <0.054 <0.054 <0.054 <0.054 0.075 0.068 <0.054 0.143 S6 8d S6 Initial >50 Sample 8/12/2015 0.25 <0.02UJ <0.02UJ <0.02UJ 16J <0.02UJ 51J 6.10J 73.1 GSI Job No. 6239
PCB-1016 PCB-1221 PCB-1232 PCB-1242 PCB-1248 PCB-1254 PCB-1260 Total PCBs
depth
(feet bgs)
EPA Method 8082 (mg/kg)
TABLE 1. POLYCHLORINATED BIPHENYLS (PCBs) in SOIL
Former Riverside Scrap Iron & Metal Property
Riverside, California
Sample/
Boring
ID
Area Sample
Location
2018 Investigation
Step-Out Sample
Designation or
Information
Sample Date
Remedial Action Plan
S6X-2.5 8d S6 X 1/23/2018 2.5 <0.054 <0.054 <0.054 <0.054 0.4 0.52 <0.054 0.92 S6A-1 8d S6 A 1/23/2018 1 <0.054 <0.054 <0.054 <0.054 <0.054 0.062 <0.054 0.062 S6A-2.5 8d S6 A 1/23/2018 2.5 <0.054 <0.054 <0.054 <0.054 <0.054 0.12 <0.054 0.12 S6B-1 8d S6 B 1/23/2018 1 <0.053 <0.053 <0.053 <0.053 0.096 0.44 <0.053 0.536 S6B-2.5 8d S6 B 1/23/2018 2.5 <0.053 <0.053 <0.053 <0.053 0.078 0.32 <0.053 0.398 S6C-1 8d S6 C 1/23/2018 1 <0.054 <0.054 <0.054 <0.054 <0.054 <0.054 <0.054 All ND S6C-2.5 8d S6 C 1/23/2018 2.5 <0.053 <0.053 <0.053 <0.053 <0.053 <0.053 <0.053 All ND S6D-1 8d S6 D 1/23/2018 1 <0.054 <0.054 <0.054 <0.054 0.39 0.66 <0.054 1.05 S6D-2.5 8d S6 D 1/23/2018 2.5 <0.055 <0.055 <0.055 <0.055 <0.055 <0.055 <0.055 All ND Area 8E
A8e-SB1 8e SB1 NA 1/25/2011 1 <0.05 <0.1 <0.05 <0.05 <0.05 0.219 <0.05 0.219 A8e-SB2 8e SB2 NA 1/25/2011 1 <0.05 <0.1 <0.05 <0.05 <0.05 0.109 <0.05 0.109 A8e-SB3 8e SB3 NA 1/25/2011 1 <0.05 <0.1 <0.05 <0.05 <0.05 <0.05 <0.05 All ND A8e-SB5 8e SB5 NA 1/26/2011 1 <0.05 <0.1 <0.05 <0.05 <0.05 <0.05 <0.05 All ND A8e-SB6 8e SB6 NA 1/26/2011 1 <0.05 <0.1 <0.05 <0.05 <0.05 1.43 <0.05 1.43 A8e-SB7 8e SB7 NA 1/26/2011 1 <0.05 <0.1 <0.05 <0.05 <0.05 <0.05 <0.05 All ND A8e-SB8 8e SB8 NA 1/26/2011 1 <0.05 <0.1 <0.05 <0.05 <0.05 <0.05 <0.05 All ND NS1 8e NS1 NA 8/10/2015 0.25 <0.02 <0.02 <0.02 <0.02 <0.02 0.094 0.057 0.151 NS24 8e NS24 NA 8/10/2015 0.25 <0.02 <0.02 <0.02 <0.02 <0.02 0.024 0.021 0.045 NS24 8e NS24 NA 8/10/2015 2.5 <0.02UJ <0.02UJ <0.02UJ <0.02UJ <0.02UJ <0.02UJ <0.02UJ All ND NS4 8e NS4 NA 8/10/2015 2.5 <0.02 <0.02 <0.02 <0.02 <0.02 0.13 0.033 0.163 NS6 8e NS6 NA 8/10/2015 2.5 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 All ND S1 8e S1 NA 8/11/2015 0.25 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 All ND S1 8e S1 NA 8/11/2015 2.5 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 All ND S2 8e S2 NA 8/12/2015 0.25 <0.02 <0.02 <0.02 <0.02 <0.02 0.051 <0.02 0.051 S2 8e S2 NA 8/12/2015 2.5 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 All ND A8e-SB4 8e SB4 Initial >50 Sample 1/25/2011 1 <0.05 <0.1 <0.05 <0.05 <0.05 <0.05 62.8 62.8 A8e-SB4X-2.5 8e SB4 X 1/23/2018 2.5 <0.055 <0.055 <0.055 <0.055 <0.055 <0.055 <0.055 All ND A8e-SB4A-1 8e SB4 A 1/23/2018 1 <0.056 <0.056 <0.056 <0.056 <0.056 <0.056 <0.056 All ND A8e-SB4A-2.5 8e SB4 A 1/23/2018 2.5 <0.055 <0.055 <0.055 <0.055 <0.055 <0.055 <0.055 All ND A8e-SB4B-1 8e SB4 B 1/23/2018 1 <0.055 <0.055 <0.055 <0.055 0.35 0.39 <0.055 0.74 A8e-SB4B-2.5 8e SB4 B 1/23/2018 2.5 <0.056 <0.056 <0.056 <0.056 <0.056 <0.056 <0.056 All ND A8e-SB4C-1 8e SB4 C 1/23/2018 1 <5.7 <5.7 <5.7 <5.7 48 76 <5.7 124 A8e-SB4C-2.5 8e SB4 C 1/23/2018 2.5 <0.055 <0.055 <0.055 <0.055 <0.055 <0.055 <0.055 All ND A8e-SB4D-1 8e SB4 D 1/23/2018 1 <0.056 <0.056 <0.056 <0.056 0.16 0.39 <0.056 0.55 A8e-SB4D-2.5 8e SB4 D 1/23/2018 2.5 <0.055 <0.055 <0.055 <0.055 <0.055 <0.055 <0.055 All ND A8e-SB4E-0.5 8e SB4 E 5/18/2018 0.5 <0.053 <0.053 <0.053 <0.053 0.17 0.2 <0.053 0.37 A8e-SB4E-1 8e SB4 E 5/18/2018 1 <0.055 <0.055 <0.055 <0.055 0.11 0.072 <0.055 0.182 A8e-SB4F-0.5 8e SB4 F 5/18/2018 0.5 <0.053 <0.053 <0.053 <0.053 0.18 0.25 0.11 0.54 A8e-SB4F-1 8e SB4 F 5/18/2018 1 <0.057 <0.057 <0.057 <0.057 <0.057 <0.057 <0.057 All ND A8e-SB4G-0.5 8e SB4 G 5/18/2018 0.5 <0.052 <0.052 <0.052 <0.052 0.17 0.71 <0.052 0.88 A8e-SB4G-1 8e SB4 G 5/18/2018 1 <0.054 <0.054 <0.054 <0.054 <0.054 <0.054 <0.054 All ND GSI Job No. 6239
PCB-1016 PCB-1221 PCB-1232 PCB-1242 PCB-1248 PCB-1254 PCB-1260 Total PCBs
depth
(feet bgs)
EPA Method 8082 (mg/kg)
TABLE 1. POLYCHLORINATED BIPHENYLS (PCBs) in SOIL
Former Riverside Scrap Iron & Metal Property
Riverside, California
Sample/
Boring
ID
Area Sample
Location
2018 Investigation
Step-Out Sample
Designation or
Information
Sample Date
Remedial Action Plan
Area 8F
A8f-SB1 8f SB1 NA 1/25/2011 1 <0.05 <0.1 <0.05 <0.05 <0.05 <0.05 <0.05 All ND A8f-SB2 8f SB2 NA 1/25/2011 1 <0.05 <0.1 <0.05 <0.05 <0.05 0.161 <0.05 0.161 A8f-SB3 8f SB3 NA 1/25/2011 1 <0.05 <0.1 <0.05 <0.05 <0.05 3.07 <0.05 3.07 NS3 8f NS3 NA 8/10/2015 0.25 <0.02 <0.02 <0.02 <0.02 <0.02 0.047 0.043 0.09 NS5 8f NS5 NA 8/10/2015 2.5 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 All ND S3 8f S3 NA 8/11/2015 0.25 <0.02 <0.02 <0.02 <0.02 <0.02 0.076 0.047 0.123 S3 8f S3 NA 8/11/2015 2.5 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 All ND Area 8G
A8g-SB1 8g SB1 NA 1/26/2011 1 <0.05 <0.1 <0.05 <0.05 <0.05 <0.05 <0.05 All ND A8g-SB2 8g SB2 NA 1/26/2011 1 <0.05 <0.1 <0.05 <0.05 <0.05 <0.05 <0.05 All ND A8g-SB3 8g SB3 NA 1/26/2011 1 <0.05 <0.1 <0.05 <0.05 <0.05 <0.05 <0.05 All ND S17 8g S17 NA 8/14/2015 0.25 <0.02 <0.02 <0.02 0.026 <0.02 0.06 0.03 0.116 S19 8g S19 NA 8/14/2015 0.25 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 All ND S19 8g S19 NA 8/14/2015 2.5 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 All ND Area 8H
A8h-SB1 8h SB1 NA 1/28/2011 1 <0.05 <0.1 <0.05 <0.05 <0.05 <0.05 <0.05 All ND A8h-SB10 8h SB10 NA 1/28/2011 1 <0.05 <0.1 <0.05 <0.05 <0.05 <0.05 <0.05 All ND A8h-SB2 8h SB2 NA 1/28/2011 1 <0.05 <0.1 <0.05 <0.05 <0.05 1.3 <0.05 1.3 A8h-SB3 8h SB3 NA 1/28/2011 1 <0.05 <0.1 <0.05 <0.05 1.18 0.699 <0.05 1.879 A8h-SB4 8h SB4 NA 1/28/2011 1 <0.05 <0.1 <0.05 <0.05 1.57 0.552 <0.05 2.122 A8h-SB5 8h SB5 NA 1/28/2011 1 <0.05 <0.1 <0.05 <0.05 <0.05 <0.05 <0.05 All ND A8h-SB6 8h SB6 NA 1/28/2011 1 <0.05 <0.1 <0.05 <0.05 0.054 <0.05 <0.05 0.054 A8h-SB7 8h SB7 NA 1/28/2011 1 <0.05 <0.1 <0.05 <0.05 1.73 1.81 <0.05 3.54 A8h-SB8 8h SB8 NA 1/28/2011 1 <0.05 <0.1 <0.05 <0.05 1.49 0.536 <0.05 2.026 A8h-SB9 8h SB9 NA 1/28/2011 1 <0.05 <0.1 <0.05 <0.05 <0.05 <0.05 <0.05 All ND ES3 8h ES3 NA 8/14/2015 0.25 <0.02 <0.02 <0.02 0.2 <0.02 0.41 0.17 0.78 S18 8h S18 NA 8/14/2015 2.5 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 All ND NS17 8h NS17 NA 8/21/2015 2.5 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 All ND NS18 8h NS18 NA 8/21/2015 0.25 <0.02UJ <0.02UJ <0.02UJ .250J <0.02UJ .420J 0.150J 0.82 NS18 8h NS18 NA 8/21/2015 2.5 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 All ND NS19 8h NS19 NA 8/21/2015 2.5 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 All ND NS20 8h NS20 NA 8/21/2015 2.5 <0.02UJ <0.02UJ <0.02UJ 3.2J <0.02UJ 1.500J 1.1J 5.8 NS20 8h NS20 NA 8/21/2015 5 <0.02UJ <0.02UJ <0.02UJ 1.1J <0.02UJ .480J 0.290J 1.87 NS21 8h NS21 NA 8/21/2015 2.5 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 All ND Area 10A
A10a-SB1 10a SB1 NA 1/28/2011 1 <0.05 <0.1 <0.05 <0.05 <0.05 <0.05 <0.05 All ND A10a-SB2 10a SB2 NA 1/28/2011 1 <0.05 <0.1 <0.05 <0.05 <0.05 <0.05 <0.05 All ND ES1 10a ES1 NA 8/19/2015 0.25 <0.2 <0.2 <0.2 <0.2 <0.2 <0.2 <0.2 All ND ES1 10a ES1 NA 8/19/2015 2.5 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 All ND GSI Job No. 6239
PCB-1016 PCB-1221 PCB-1232 PCB-1242 PCB-1248 PCB-1254 PCB-1260 Total PCBs
depth
(feet bgs)
EPA Method 8082 (mg/kg)
TABLE 1. POLYCHLORINATED BIPHENYLS (PCBs) in SOIL
Former Riverside Scrap Iron & Metal Property
Riverside, California
Sample/
Boring
ID
Area Sample
Location
2018 Investigation
Step-Out Sample
Designation or
Information
Sample Date
Remedial Action Plan
Area 10B
A10b-SB1 10b SB1 NA 1/26/2011 1 <0.05 <0.1 <0.05 <0.05 <0.05 0.112 <0.05 0.112 A10b-SB2 10b SB2 NA 1/26/2011 1 <0.05 <0.1 <0.05 <0.05 2.19 1.29 <0.05 3.48 A10b-SB3 10b SB3 NA 1/26/2011 1 <0.05 <0.1 <0.05 <0.05 <0.05 7.12 <0.05 7.12 S15 10b S15 NA 8/12/2015 0.25 <0.02UJ <0.02UJ <0.02UJ 0.230J <0.02UJ 0.095J 0.023J 0.348 S15 10b S15 NA 8/12/2015 2.5 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 0 NS11 10b NS11 NA 8/11/2015 2.5 <0.02 <0.02 <0.02 <0.02 <0.02 0.039 0.027 0.066 NS12 10b NS12 NA 8/13/2015 2.5 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 All ND NS13 10b NS13 NA 8/13/2015 2.5 <0.02 <0.02 <0.02 0.071 <0.02 0.076 0.032 0.179 S14 10b S14 Initial >50 Sample 8/13/2015 1 <0.2 <0.2 <0.2 48J <0.02 50J 18.0J 116 S14 10b S14 Initial >50 Sample 8/13/2015 2.5 <0.02 <0.02 <0.02 <0.02 <0.02 0.038 <0.02 0.038 S14 10b S14 Initial >50 Sample 8/13/2015 0.25 <0.02UJ <0.02UJ <0.02UJ 2.9J <0.02UJ 15J 9.30J 27.2 S14A-1 10b S14 A 1/23/2018 1 <5.7 <5.7 <5.7 <5.7 50 33 22 105 S14A-2.5 10b S14 A 1/23/2018 2.5 <0.057 <0.057 <0.057 <0.057 0.097 <0.057 <0.057 0.097 S14B-1 10b S14 B 1/23/2018 1 <2.8 <2.8 <2.8 <2.8 14 13 10 37 S14B-2.5 10b S14 B 1/23/2018 2.5 <0.056 <0.056 <0.056 <0.056 <0.056 <0.056 <0.056 0 S14C-1 10b S14 C 1/23/2018 1 <0.54 <0.54 <0.54 <0.54 8.5 11 11 30.5 S14C-2.5 10b S14 C 1/23/2018 2.5 <5.5 <5.5 <5.5 <5.5 82 47 8.9 137.9 S14C-5 10b S14 C 1/23/2018 5 <0.055 <0.055 <0.055 <0.055 0.28 0.23 <0.055 0.51 S14D-1 10b S14 D 1/23/2018 1 <3 <3 <3 <3 43 36 22 101
S14D-2.5 10b S14 D 1/23/2018 2.5 <0.056 <0.056 <0.056 <0.056 <0.056 <0.056 <0.056 All ND S14BB-0.5 10b S14 BB 5/18/2018 0.5 <0.52 <0.52 <0.52 <0.52 9.3 7.8 8.3 25 S14BB-1 10b S14 BB 5/18/2018 1 <0.54 <0.54 <0.54 <0.54 7.1 8.4 9.2 25 S14E-0.5 10b S14 E 5/18/2018 0.5 <0.55 <0.55 <0.55 <0.55 6.7 <0.55 260 270 S14E-1 10b S14 E 5/18/2018 1 <0.57 <0.57 <0.57 <0.57 39 13 4 56 S14F-0.5 10b S14 F 5/18/2018 0.5 <5.2 <5.2 <5.2 <5.2 16 9.7 10 36 S14F-1 10b S14 F 5/18/2018 1 <2.7 <2.7 <2.7 <2.7 17 <2.7 37 53 S14G-0.5 10b S14 G 5/18/2018 0.5 <2.6 <2.6 <2.6 <2.6 9.4 9.4 10 29 S14G-1 10b S14 G 5/18/2018 1 <2.7 <2.7 <2.7 <2.7 11 14 32 57 S14G-2.5 10b S14 G 5/18/2018 2.5 <0.26 <0.26 <0.26 <0.26 0.6 2.5 5.2 8.2 S14H-0.5 10b S14 H 5/18/2018 0.5 <2.5 <2.5 <2.5 <2.5 12 10 12 34 S14H-1 10b S14 H 5/18/2018 1 <2.7 <2.7 <2.7 <2.7 9.7 8 8.9 27 S14H-2.5 10b S14 H 5/18/2018 2.5 <0.052 <0.052 <0.052 <0.052 0.23 0.32 0.52 1.1 S14I-0.5 10b S14 I 5/18/2018 0.5 <5.4 <5.4 <5.4 <5.4 13 8.4 8.8 30 S14I-1 10b S14 I 5/18/2018 1 <2.7 <2.7 <2.7 <2.7 3.7 <2.7 12 16 S14I-2.5 10b S14 I 5/18/2018 2.5 <2.7 <2.7 <2.7 <2.7 6.3 <2.7 28 34 S14J-0.5 10b S14 J 5/18/2018 0.5 <0.053 <0.053 <0.053 <0.053 0.26 0.089 0.064 0.42 S14J-1 10b S14 J 5/18/2018 1 <0.61 <0.61 <0.61 <0.61 1.1 <0.61 30 31 S14K-0.5 10b S14 K 5/18/2018 0.5 <0.52 <0.52 <0.52 <0.52 4.3 3 3.5 11 S14K-1 10b S14 K 5/18/2018 1 <6 <6 <6 <6 13 13 20 46
S14L-0.5 10b S14 L 5/18/2018 0.5 <0.25 <0.25 <0.25 <0.25 1.4 <0.25 1.3 2.7 S14L-1 10b S14 L 5/18/2018 1 <0.55 <0.55 <0.55 <0.55 6.1 <0.55 57 64 S14M-0.5 10b S14 M 5/18/2018 0.5 <0.51 <0.51 <0.51 <0.51 5.7 <0.51 75 81 GSI Job No. 6239
PCB-1016 PCB-1221 PCB-1232 PCB-1242 PCB-1248 PCB-1254 PCB-1260 Total PCBs
depth
(feet bgs)
EPA Method 8082 (mg/kg)
TABLE 1. POLYCHLORINATED BIPHENYLS (PCBs) in SOIL
Former Riverside Scrap Iron & Metal Property
Riverside, California
Sample/
Boring
ID
Area Sample
Location
2018 Investigation
Step-Out Sample
Designation or
Information
Sample Date
Remedial Action Plan
S14M-1 10b S14 M 5/18/2018 1 <0.54 <0.54 <0.54 <0.54 3.5 <0.54 28 31 S14E1-0.5 10b S14 E1 7/26/2018 0.5 <0.53 <0.53 <0.53 <0.53 <0.53 <0.53 7.2 7.2 S14EE-2.5 10b S14 EE 7/26/2018 2.5 <0.052 <0.052 <0.052 <0.052 0.085 <0.052 <0.052 0.085 S14FF-2.5 10b S14 FF 7/26/2018 2.5 <0.054 <0.054 <0.054 <0.054 1.6 1.1 0.43 3.1 S14FF1-1 10b S14 FF1 7/26/2018 1 <2.6 <2.6 <2.6 <2.6 12 19 15 46 S14G1-1 10b S14 G1 7/26/2018 1 <2.6 <2.6 <2.6 <2.6 12 15 12 39 S14G2-1 10b S14 G2 7/26/2018 1 <2.6 <2.6 <2.6 <2.6 9.8 14 11 35 S14LL-2.5 10b S14 LL 7/26/2018 2.5 <0.055 <0.055 <0.055 <0.055 0.17 <0.055 0.2 0.37 S14LL1-1 10b S14 LL1 7/26/2018 1 <0.55 <0.55 <0.55 <0.55 3.3 3.3 2.7 9.4 S14LL2-1 10b S14 LL2 7/26/2018 1 <0.54 <0.54 <0.54 <0.54 6.9 <0.54 1.3 8.2 S14LL3-0.5 10b S14 LL3 7/26/2018 0.5 <0.52 <0.52 <0.52 <0.52 9.4 6.9 1.7 18 S14LL3-1 10b S14 LL3 7/26/2018 1 <0.056 <0.056 <0.056 <0.056 15 12 13 40 S14M1-0.5 10b S14 M1 7/26/2018 0.5 <2.5 <2.5 <2.5 <2.5 17 12 7.5 36 S14M1-1 10b S14 M1 7/26/2018 1 <2.6 <2.6 <2.6 <2.6 44 <2.6 5 49 A10b-SB4 10b SB4 Initial >50 Sample 1/26/2011 1 <0.05 <0.1 <0.05 <0.05 <0.05 <0.05 73.8 73.8 A10b-SB4X-2.5 10b SB4 X 1/23/2018 2.5 <0.055 <0.055 <0.055 <0.055 0.087 <0.055 0.35 0.44 A10b-SB4A-1 10b SB4 A 1/23/2018 1 <5.6 <5.6 <5.6 <5.6 <5.6 <5.6 37 37 A10b-SB4A-2.5 10b SB4 A 1/23/2018 2.5 <0.055 <0.055 <0.055 <0.055 <0.055 <0.055 0.14 0.14 A10b-SB4B-1 10b SB4 B 1/23/2018 1 <28 <28 <28 <28 <28 <28 140 140 A10b-SB4B-2.5 10b SB4 B 1/23/2018 2.5 <0.056 <0.056 <0.056 <0.056 <0.056 <0.056 0.24 0.24 A10b-SB4C-1 10b SB4 C 1/23/2018 1 <0.055 <0.055 <0.055 <0.055 <0.055 <0.055 1.1 1.2 A10b-SB4C-2.5 10b SB4 C 1/23/2018 2.5 <0.054 <0.054 <0.054 <0.054 <0.054 <0.054 0.13 0.13 A10b-SB4D-1 10b SB4 D 1/23/2018 1 <5.6 <5.6 <5.6 <5.6 <5.6 <5.6 19 19 A10b-SB4D-2.5 10b SB4 D 1/23/2018 2.5 <0.055 <0.055 <0.055 <0.055 <0.055 <0.055 0.12 0.12 A10b-SB4AA-0.5 10b SB4 AA 5/18/2018 0.5 <0.52 <0.52 <0.52 <0.52 6.8 <0.52 87 94 A10b-SB4AA-1 10b SB4 AA 5/18/2018 1 <0.054 <0.054 <0.054 <0.054 <0.054 <0.054 <0.054 All ND A10b-SB4E-0.5 10b SB4 E 5/18/2018 0.5 <1.1 <1.1 <1.1 <1.1 2.7 <1.1 26 29 A10b-SB4E-1 10b SB4 E 5/18/2018 1 <0.28 <0.28 <0.28 <0.28 0.72 <0.28 21 22 A10b-SB4F-0.5 10b SB4 F 5/18/2018 0.5 <0.056 <0.056 <0.056 <0.056 0.26 0.31 0.46 1 A10b-SB4F-1 10b SB4 F 5/18/2018 1 <0.055 <0.055 <0.055 <0.055 <0.055 <0.055 0.096 0.096 A10b-SB4G-0.5 10b SB4 G 5/18/2018 0.5 <0.27 <0.27 <0.27 <0.27 0.91 1.8 2.1 4.8 A10b-SB4G-1 10b SB4 G 5/18/2018 1 <27 <27 <27 <27 <27 <27 2600 2600 A10b-SB4J-0.5 10b SB4 J 5/18/2018 0.5 <0.27 <0.27 <0.27 <0.27 0.32 0.64 1.3 2.2 A10b-SB4J-1 10b SB4 J 5/18/2018 1 <0.055 <0.055 <0.055 <0.055 0.057 <0.055 0.13 0.19 A10b-SB4K-0.5 10b SB4 K 5/18/2018 0.5 <0.054 <0.054 <0.054 <0.054 0.11 <0.054 2.4 2.5 A10b-SB4K-1 10b SB4 K 5/18/2018 1 <27 <27 <27 <27 <27 <27 180 180 SB4AA1-0.5 10b SB4 AA 7/26/2018 0.5 <5.4 <5.4 <5.4 <5.4 <5.4 <5.4 55 55 SB4AA1-1 10b SB4 AA 7/26/2018 1 <0.054 <0.054 <0.054 <0.054 <0.054 <0.054 0.24 0.24 SB4AA2-0.5 10b SB4 AA2 7/26/2018 0.5 <5.2 <5.2 <5.2 <5.2 <5.2 <5.2 50 50 SB4AA2-1 10b SB4 AA2 7/26/2018 1 <0.53 <0.53 <0.53 <0.53 0.54 <0.53 2.4 2.9 SB4AA7-0.5 10b SB4 AA7 9/27/2018 0.5 <2.5 <2.5 <2.5 <2.5 <2.5 <2.5 13 13 SB4AA7-1.0 10b SB4 AA7 9/27/2018 1 <0.052 <0.052 <0.052 <0.052 <0.052 <0.052 <0.052 All ND SB4AA8-0.5 10b SB4 AA8 9/27/2018 0.5 <0.51 <0.51 <0.51 <0.51 <0.51 <0.51 4.2 4.2 SB4AA8-1.0 10b SB4 AA8 9/27/2018 1 <0.052 <0.052 <0.052 <0.052 <0.052 <0.052 <0.052 All ND GSI Job No. 6239
PCB-1016 PCB-1221 PCB-1232 PCB-1242 PCB-1248 PCB-1254 PCB-1260 Total PCBs
depth
(feet bgs)
EPA Method 8082 (mg/kg)
TABLE 1. POLYCHLORINATED BIPHENYLS (PCBs) in SOIL
Former Riverside Scrap Iron & Metal Property
Riverside, California
Sample/
Boring
ID
Area Sample
Location
2018 Investigation
Step-Out Sample
Designation or
Information
Sample Date
Remedial Action Plan
SB4GG-2.5 10b SB4 GG 7/26/2018 2.5 <0.055 <0.055 <0.055 <0.055 <0.055 <0.055 <0.055 All ND SB4KK1-1 10b SB4 KK 7/26/2018 1 <5.5 <5.5 <5.5 <5.5 <5.5 <5.5 110 110 SB4KK-2.5 10b SB4 KK 7/26/2018 2.5 <0.054 <0.054 <0.054 <0.054 <0.054 <0.054 <0.054 All ND SB4KK1-2.5 10b SB4 KK1 7/26/2018 2.5 <0.055 <0.055 <0.055 <0.055 <0.055 <0.055 <0.055 All ND SB4KK2-1 10b SB4 KK2 7/26/2018 1 <5.4 <5.4 <5.4 <5.4 <5.4 <5.4 27 27 SB4KK3-1 10b SB4 KK3 7/26/2018 1 <5.4 <5.4 <5.4 <5.4 <5.4 <5.4 21 21 SB4AA3-0.5 10b SB4 AA3 8/3/2018 0.5 <0.26 <0.26 <0.26 <0.26 <0.26 <0.26 1.7 1.7 SB4AA3-1 10b SB4 AA3 8/3/2018 1 <0.054 <0.054 <0.054 <0.054 <0.054 <0.054 0.85 0.85 SB4AA4-0.5 10b SB4 AA4 8/3/2018 0.5 <25 <25 <25 <25 <25 <25 140 140 SB4AA4-1 10b SB4 AA4 8/3/2018 1 <0.053 <0.053 <0.053 <0.053 <0.053 <0.053 0.058 0.058 SB4AA5-0.5 10b SB4 AA5 8/3/2018 0.5 <0.051 <0.051 <0.051 <0.051 <0.051 <0.051 0.1 0.1 SB4AA5-1 10b SB4 AA5 8/3/2018 1 <0.052 <0.052 <0.052 <0.052 <0.052 <0.052 <0.052 All ND SB4AA6-0.5 10b SB4 AA6 8/3/2018 0.5 <0.055 <0.055 <0.055 <0.055 <0.055 <0.055 0.072 0.072 SB4AA6-1 10b SB4 AA6 8/3/2018 1 <0.055 <0.055 <0.055 <0.055 <0.055 <0.055 0.31 0.31 SB4KK4-1 10b SB4 KK4 8/3/2018 1 <27 <27 <27 <27 <27 <27 170 170 SB4KK4-2.5 10b SB4 KK4 8/3/2018 2.5 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 0.06 0.06 SBKK5-1 10b SB4 KK5 8/3/2018 1 <54 <54 <54 <54 70 <54 140 210 SB4KK5-2.5 10b SB4 KK5 8/3/2018 2.5 <0.056 <0.056 <0.056 <0.056 <0.056 <0.056 0.21 0.21 SB4KK6-0.5 10b SB4 KK6 9/27/2018 0.5 <0.5 <0.5 <0.5 <0.5 4.5 2.9 2.1 9.5 SB4KK6-1.0 10b SB4 KK6 9/27/2018 1 <2.7 <2.7 <2.7 <2.7 <2.7 <2.7 11 11 SB4KK7-0.5 10b SB4 KK7 9/27/2018 0.5 <0.25 <0.25 <0.25 <0.25 1.6 0.81 0.69 3.1 SB4KK7-1.0 10b SB4 KK7 9/27/2018 1 <5.4 <5.4 <5.4 <5.4 19 <5.4 87 110 SB4KK7-2.5 10b SB4 KK7 9/27/2018 2.5 <0.056 <0.056 <0.056 <0.056 <0.056 <0.056 <0.056 All ND SB4KK8-0.5 10b SB4 KK8 9/27/2018 0.5 <0.5 <0.5 <0.5 <0.5 2.2 1.1 0.84 4.1 SB4KK8-1.0 10b SB4 KK8 9/27/2018 1 <5.4 <5.4 <5.4 <5.4 <5.4 <5.4 76 76 SB4KK9-0.5 10b SB4 KK9 9/27/2018 0.5 <0.26 <0.26 <0.26 <0.26 1.5 0.39 <0.26 2.1 SB4KK9-1.0 10b SB4 KK9 9/27/2018 1 <0.055 <0.055 <0.055 <0.055 <0.055 <0.055 0.88 0.88 SB4KK11-0.5 10b SB4 KK11 9/27/2018 0.5 <0.5 <0.5 <0.5 <0.5 30 7.7 4 41 SB4KK11-1.0 10b SB4 KK11 9/27/2018 1 <0.54 <0.54 <0.54 <0.54 <0.54 <0.54 76 76 SB4KK11-2.5 10b SB4 KK11 9/27/2018 2.5 <0.057 <0.057 <0.057 <0.057 <0.057 <0.057 <0.057 All ND SB4KK12-0.5 10b SB4 KK12 9/27/2018 0.5 <0.054 <0.054 <0.054 <0.054 <0.054 <0.054 <0.054 All ND SB4KK12-1.0 10b SB4 KK12 9/27/2018 1 <0.055 <0.055 <0.055 <0.055 <0.055 <0.055 <0.055 All ND SB4KK12-2.5 10b SB4 KK12 9/27/2018 2.5 <0.055 <0.055 <0.055 <0.055 <0.055 <0.055 <0.055 All ND SB4KK13-0.5 10b SB4 KK13 9/27/2018 0.5 <0.05 <0.05 <0.05 <0.05 0.45 0.43 0.37 1.3 SB4KK13-1.0 10b SB4 KK13 9/27/2018 1 <2.8 <2.8 <2.8 <2.8 18 <2.8 59 77 SB4KK13-2.5 10b SB4 KK13 9/27/2018 2.5 <0.054 <0.054 <0.054 <0.054 <0.054 <0.054 <0.054 All ND SB4KK14-0.5 10b SB4 KK14 9/27/2018 0.5 <0.05 <0.05 <0.05 <0.05 3.4 3 3.2 9.6 SB4KK14-1.0 10b SB4 KK14 9/27/2018 1 <0.055 <0.055 <0.055 <0.055 <0.055 <0.055 13 13 SB4KK14-2.5 10b SB4 KK14 9/27/2018 2.5 <0.055 <0.055 <0.055 <0.055 <0.055 <0.055 <0.055 All ND SB4KK17-0.5 10b SB4 KK17 12/20/2018 0.5 <0.055 <0.055 <0.055 <0.055 0.083 0.088 0.08 0.25 SB4KK17-1 10b SB4 KK17 12/20/2018 1 <0.055 <0.055 <0.055 <0.055 <0.055 <0.055 <0.055 All ND SB4KK18-0.5 10b SB4 KK18 12/20/2018 0.5 <0.055 <0.055 <0.055 <0.055 <0.055 <0.055 12 12 SB4KK18-1 10b SB4 KK18 12/20/2018 1 <0.055 <0.055 <0.055 <0.055 <0.055 <0.055 0.53 0.53 SB4KK19-0.5 10b SB4 KK19 12/20/2018 0.5 <0.055 <0.055 <0.055 <0.055 1.9 2.8 2.9 7.6 GSI Job No. 6239
PCB-1016 PCB-1221 PCB-1232 PCB-1242 PCB-1248 PCB-1254 PCB-1260 Total PCBs
depth
(feet bgs)
EPA Method 8082 (mg/kg)
TABLE 1. POLYCHLORINATED BIPHENYLS (PCBs) in SOIL
Former Riverside Scrap Iron & Metal Property
Riverside, California
Sample/
Boring
ID
Area Sample
Location
2018 Investigation
Step-Out Sample
Designation or
Information
Sample Date
Remedial Action Plan
SB4KK19-1 10b SB4 KK19 12/20/2018 1 <0.055 <0.055 <0.055 <0.055 110 <0.055 7 120 SB4KK20-0.5 10b SB4 KK20 12/20/2018 0.5 <0.055 <0.055 <0.055 <0.055 <0.055 <0.055 11 11 SB4KK20-1 10b SB4 KK20 12/20/2018 1 <0.055 <0.055 <0.055 <0.055 90 <0.055 4.5 95 SB4KK19-2.5 10b SB4 KK19 12/20/2018 2.5 <0.056 <0.056 <0.056 <0.056 0.12 <0.056 <0.056 0.12 SB4KK19-5 10b SB4 KK19 12/20/2018 5 <0.056 <0.056 <0.056 <0.056 0.26 <0.056 0.12 0.38 SB4KK20-2.5 10b SB4 KK20 12/20/2018 2.5 <0.056 <0.056 <0.056 <0.056 <0.056 <0.056 <0.056 All ND SB4KK20-5 10b SB4 KK20 12/20/2018 5 <0.056 <0.056 <0.056 <0.056 <0.056 <0.056 <0.056 All ND SB4KK24-0.5 10b SB4 KK24 12/20/2018 0.5 <0.056 <0.056 <0.056 <0.056 33 <0.056 1.8 35 SB4KK24-1 10b SB4 KK24 12/20/2018 1 <0.056 <0.056 <0.056 <0.056 30 <0.056 1.7 32 SB4KK24-2.5 10b SB4 KK24 12/20/2018 2.5 <0.056 <0.056 <0.056 <0.056 0.32 <0.056 0.058 0.37 SB4KK24-5 10b SB4 KK24 12/20/2018 5 <0.056 <0.056 <0.056 <0.056 0.07 <0.056 <0.056 0.07 SB4KK25-0.5 10b SB4 KK25 12/20/2018 0.5 <0.056 <0.056 <0.056 <0.056 0.83 <0.056 3.4 4.3 SB4KK25-1 10b SB4 KK25 12/20/2018 1 <0.056 <0.056 <0.056 <0.056 7.5 <0.056 0.28 7.8 SB4KK25-2.5 10b SB4 KK25 12/20/2018 2.5 <0.056 <0.056 <0.056 <0.056 <0.056 <0.056 <0.056 All ND SB4KK25-5 10b SB4 KK25 12/20/2018 5 <0.056 <0.056 <0.056 <0.056 <0.056 <0.056 <0.056 All ND SB4KK26-0.5 10b SB4 KK26 12/20/2018 0.5 <0.056 <0.056 <0.056 <0.056 0.91 3.1 2.5 6.5 SB4KK26-1 10b SB4 KK26 12/20/2018 1 <0.056 <0.056 <0.056 <0.056 87 <0.056 6.4 93 SB4KK26-2.5 10b SB4 KK26 12/20/2018 2.5 <0.056 <0.056 <0.056 <0.056 <0.056 <0.056 <0.056 All ND SB4KK26-5 10b SB4 KK26 12/20/2018 5 <0.056 <0.056 <0.056 <0.056 <0.056 <0.056 <0.056 All ND Area 12
A12-SB1 12 SB1 NA 1/31/2011 1 <0.05 <0.1 <0.05 <0.05 <0.05 <0.05 23 23 A12-SB2 12 SB2 NA 1/31/2011 1 <0.05 <0.1 <0.05 <0.05 <0.05 <0.05 <0.05 All ND A12-SB3 12 SB3 NA 1/31/2011 1 <0.05 <0.1 <0.05 <0.05 0.123 <0.05 <0.05 0.123 A12-SB4 12 SB4 NA 1/31/2011 1 <0.05 <0.1 <0.05 <0.05 0.205 0.12 <0.05 0.325 A12-SB5 12 SB5 NA 1/31/2011 1 <0.05 <0.1 <0.05 <0.05 <0.05 <0.05 6.2 6.2 S10 12 S10 NA 8/11/2015 0.25 <0.02UJ <0.02UJ <0.02UJ 1.4J <0.02UJ 4.3J 3.50J 9.2 S10 12 S10 NA 8/11/2015 2.5 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 All ND S7 12 S7 NA 8/11/2015 2.5 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 All ND NS16 12 NS16 NA 8/13/2015 2.5 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 All ND GSI Job No. 6239
PCB-1016 PCB-1221 PCB-1232 PCB-1242 PCB-1248 PCB-1254 PCB-1260 Total PCBs
depth
(feet bgs)
EPA Method 8082 (mg/kg)
TABLE 1. POLYCHLORINATED BIPHENYLS (PCBs) in SOIL
Former Riverside Scrap Iron & Metal Property
Riverside, California
Sample/
Boring
ID
Area Sample
Location
2018 Investigation
Step-Out Sample
Designation or
Information
Sample Date
Remedial Action Plan
Area 13
A13-SB1 13 SB1 NA 1/31/2011 1 <0.05 <0.1 <0.05 <0.05 <0.05 0.425 <0.05 0.425 A13-SB2 13 SB2 NA 1/31/2011 1 <0.05 <0.1 <0.05 <0.05 <0.05 <0.05 <0.05 ALL ND A13-SB3 13 SB3 NA 2/3/2011 1 <0.05 <0.1 <0.05 <0.05 <0.05 <0.05 <0.05 ALL ND
4.1 0.2 0.17 0.23 0.23 0.24 0.24 1.0
Notes and Data Qualifiers
RBSL = Risk Based Screening Levels (Table 3)
Blue = Concentration exceeds listed RBSL
Bold Blue = Toal PCBs exceed 50 mg/kg
J = The analyte was detected at a concentration above the method detection limit, but below the reporting limit and is an approximate concentration of the analyte in the sample.
UJ = The analyte was not detected above the laboratory reporting limit but the reporting limit is approximate due either to the quality of the data generated because certain quality control criteria were not met or the sample was analyzed outside the holding time for extraction.
J-flagged results are included in the calculation of "Total PCBs" The following PCB Arochlors were not detected in any sample above laboratory reporting limits: PCB-1016, PCB-1232, PCB-1262, and PCB-1268.
Abbreviations
bgs = Below ground surface
NA = Not applicable to 2018 investigation
< = Not detected at the reporting limit shown
PCBs = Polychlorinated biphenyls
RSL = Regional soil screening level
USEPA = United States Environmental Protection Agency
mg/kg = milligrams per kilogram
Note that some Aroclor's with higher concentrations required dilution to report within calibration range, which resulted in elevated laboratory reporting limits. During excavation confirmation sampling activities, chain-of-custody instructions will note to report each Arochlor at the lowest dilution possible that either has a reportable result or ND at the applicable reporting limit.
RBSLs (Table 3)
GSI Job No. 6239
Regulated
Parameter Criteria Reference Description ARAR or TBC Notes Air State SCAQMD Regulation IV, Rule 403
Limits onsite activities so that fugitive dust at the property line shall not be visible and the downwind particulate concentration shall not be more than 100 micrograms per cubic meter, averaged over 5 hours, above the upwind particulate concentration. Also requires reasonable precaution to minimize fugitive dust and prevent and cleanup any material accidentally deposited on paved streets.
ARAR Dust generated during removal actions will be controlled.
Air State SCAQMD Regulation IV, Rule 1466
Earthwork activities in soil with the presence of toxic air contaminants listed in Rule 1466 and a volume of greater than or equal to 50 cubic yards.
ARAR
Rule 1466 procedures will be followed, as applicable, during implementation of the proposed remedial alternatives. In addition, dust control measures will be implemented to further control dust emissions on Site within the work area.
Air State SCAQMD Regulation IV, Rule 1166
Earthwork activities in soil with the presence of volatile organic compound-impacted soil.
ARAR Rule 1166 procedures will be followed, as applicable, during implementation of the proposed remedial alternatives.
Land Use State Title 22 CCR, Section 67391.1; Civil Code Section 1471; and HSC Section 25355.5.
Provisions regarding the issuance and recording of land use covenants and restrictions.
Potential TBC TBC as institutional controls are not expected since the RAP proposes removal of impacted soil to residential criteria.
Soil Federal
Toxic Substances Control Act (TSCA) (15 USC, Section
2601 et seq.); Federal PCB Regulations (40 CFR Part
761).
TSCA outlines procedures for sampling media, waste
characterization, and disposal of PCB-impacted media. ARAR PCBs are present in soil at the Site and USEPA is providing oversight of TSCA regulations.
Soil Federal U.S. Environmental Protection Agency (USEPA) Regional Screening Levels (RSLs) for soil.
USEPA-published risk-based screening levels (RBSLs) for soil that are protective of soil exposures under residential/ unrestricted land use.
TBC
If identified, contaminant levels in Site soils that exceed these risk-based criteria may require mitigation to be protective of residential/unrestricted land use. RSLs are proposed as remedial goals as outlined in Table 2 of the RAP.
Soil State
California Environmental Protection Agency (Cal/EPA),
Department of Toxic Substances Control (DTSC)
modified screening levels (SLs) (published in
Cal/EPA's Human Health Risk Assessment [HHRA]
Note Number 3).
Cal/EPA-published risk-based screening levels for soil that are protective of soil exposures under residential/ unrestricted land use, and for a number of chemicals, are more protective than USEPA RSLs for residential soil.
TBC
If identified, contaminant levels in Site soils that exceed these risk-based criteria may require mitigation to be protective of residential/unrestricted land use. DTSC- modified SLs are proposed as remedial goals as outlined in Table 2 of the RAP.
Soil State
California Regional Water Quality Control Board, San
Francisco Bay Region, Region 2 (SFRWQCB),
Environmental Screening Levels (ESLs) for TPH.
SFRWQCB-published screening levels for TPH in soil that are protective of direct exposures to TPH under residential/unrestricted land use.
TBC
If identified, TPH levels in Site soils that exceed these risk-based criteria may require mitigation to be protective of residential/unrestricted land use.
SFRWQCB ESLs for TPH are proposed as remedial goals as outlined in Table 2 of the RAP.
Waste State Title 22 CCR, Sections 66261.10 through 66261.126. Criteria for identifying the characteristics of hazardous wastes and associated record keeping. ARAR Based on Site data, generation of RCRA hazardous waste and other waste classifications are expected as part of the proposed remedial activities.
Waste Federal 40 CFR, Part 260-280 and 22 CCR, Sections 66260- 66280
Sets requirements for generators of hazardous waste concerning management, treatment, storage, and disposal. Authorizes California to enforce their own hazardous waste program under the California Hazardous Waste Act.
ARAR Based on Site data, generation of RCRA hazardous waste and other waste classifications are expected as part of the proposed remedial activities.
Risk
Assessment State DTSC Toxicity Criteria for Human Health Risk Assessment
Sets a narrative cleanup performance standard and adopts toxicity criteria for use in all human health risk assessments.
ARAR This regulation is effective 9/4/18; https://dtsc.ca.gov/regs/toxicity-criteria-for- human-health-risk-assessment/
TABLE 2. APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs) AND TO-BE-CONSIDERED CRITERIA (TBC) Remedial Action Plan
Former Riverside Scrap Iron & Metal Property
Riverside, California
GSI Job No. 6239
COC
May 2019
Remedial Goal
(mg/Kg)
Basis 2019 Source
Antimony 31 Risk-based screening level for residential soil US EPA regional screening level (US EPA, 2022) Arsenic 12 Regional background threshold value DTSC Advisory (DTSC, 2008) Beryllium 16 Risk-based screening level for residential soil DTSC-modified screening level (DTSC, 2022) Cadmium 7.1 Risk-based screening level for residential soil US EPA regional screening level (US EPA, 2022) Cobalt 23 Risk-based screening level for residential soil US EPA regional screening level (US EPA, 2022) Copper 3,100 Risk-based screening level for residential soil US EPA regional screening level (US EPA, 2022) Lead 80 Risk-based screening level for residential soil DTSC-modified screening level (DTSC, 2022) Mercury 1 Risk-based screening level for residential soil DTSC-modified screening level (DTSC, 2022) Nickel 820 Risk-based screening level for residential soil DTSC-modified screening level (DTSC, 2022) Vanadium 390 Risk-based screening level for residential soil US EPA regional screening level (US EPA, 2022) Benz[a]anthracene 1.1 Risk-based screening level for residential soil DTSC-modified screening level (DTSC, 2022) Benzo(b)fluoranthene 1.1 Risk-based screening level for residential soil US EPA regional screening level (US EPA, 2022) Benzo[a]pyrene 0.11 Risk-based screening level for residential soil US EPA regional screening level (US EPA, 2022) Benzo[a]pyrene Equivalents 0.9 Regional background threshold value DTSC Advisory (DTSC, 2009) Dibenz[a,h]anthracene 0.028 Risk-based screening level for residential soil DTSC-modified screening level (DTSC, 2022) Indeno(1,2,3-cd)pyrene 1.1 Risk-based screening level for residential soil US EPA regional screening level (US EPA, 2022) Naphthalene 2 Risk-based screening level for residential soil DTSC-modified screening level (DTSC, 2022) Total Petroleum Hydrocarbons (TPH)
TPH-gasoline 430 Risk-based screening level for residential soil SFRWQCB Environmental Screening Level (SFRWQCB 2019) TPH-diesel 260 Risk-based screening level for residential soil SFRWQCB Environmental Screening Level (SFRWQCB 2019) TPH-motor oil 12,000 Risk-based screening level for residential soil SFRWQCB Environmental Screening Level (SFRWQCB 2019) Aroclor 1016 4.1
Aroclor 1221 0.2
Aroclor 1232 0.17
Aroclor 1242 0.23
Aroclor 1248 0.23
Aroclor 1254 0.24
Aroclor 1260 0.24
Notes:
PAH = polycyclic aromatic hydrocarbons
PCBs = polychlorinated biphenyls
DTSC = California Department of Toxic Substances Control mg/kg = milligram per kilogram
References:
United States Environmental Protection Agency (USEPA), 2022. Regional Screening Levels (RSLs). https://www.epa.gov/risk/regional- screening-levels-rsls-generic-tables. May.
Risk-based screening level for residential soil
San Francisco Bay Regional Water Quality Control Board (SFRWQCB), 2019. Environmental Screening Levels (ESLs). January. https://www.waterboards.ca.gov/sanfranciscobay/water_issues/programs/esl.html TABLE 3. REMEDIAL GOALS FOR CHEMICALS OF CONCERN (COCs) IN SOIL Remedial Action Plan
Former Riverside Scrap Iron & Metal Property
Riverside, California
Metals
Polycyclic Aromatic Hydrocarbons (PAHs)
US EPA regional screening level (US EPA, 2022), as endorsed by DTSC (2022)
Polychlorinated Biphenyls (PCBs)
California Department of Toxic Substances Control (DTSC), 2022. Human Health Risk Assessment (HHRA) Note, HERO HHRA Note 3, DTSC- modified Screening Levels (DTSC-SLs). May.
California Department of Toxic Substances Control (DTSC), 2008. Determination of a Southern California Regional Background Arsenic Concentration in Soil, https://www.dtsc.ca.gov/upload/Background-Arsenic.pdf.
California Department of Toxic Substances Control (DTSC), 2009. Advisory - Use of PAH Studies in the MGP Site Cleanup Process, https://www.dtsc.ca.gov/assessingRisk/upload/MGP_PAH_Advisory_070109.pdf, July 1.
GSI Job No. 6239
PCB
Excavation
Area
Historical Area
Designation
Original
Sample
> 50 mg/kg
(Table 1)
Approximate
Area (square
feet)
Approximate
Maxium
Excavation
Depth (feet)
Estimated
Excavation
Volume (cy)
Maximum
PCBs
Identified
(mg/kg)
PCB Area 1 10b A10b SB4 1900 2.5 175.9 2600
PCB Area 2 10b S14 975 2.5 90.3 270
PCB Area 3 8b A8b SB1 225 2.5 20.8 494
PCB Area 4 8e A8e SB4 400 2.5 37.0 120
PCB Area 5 8d S6 225 2.5 20.8 73.1
PCB Area 6 8d NS2 1500 2.5 138.9 1400
Total cy 483.8
Abbreviations
PCBs = Polychlorinated biphenyls
cy = cubic yards
mg/kg = milligram per kilogram
Former Riverside Scrap Iron & Metal Property
TABLE 4. TARGETED PCB EXCAVATIONS
Remedial Action Plan
Riverside, California
GSI Job No. 6239
Historical Area
Designation
Original
Sample
Designation
Sample
Depth
(feet)
Area
(square
feet)
Maxium
Excavation
Depth (feet)
Cubic
yards
Lead
(mg/kg)
Lead Soluable
Result
10b A10b SB3 1 4,260 NA
10b S14 0.25,1 1,500
180 (WET)
10(TCLP)
8a A8a SB3 1 2,240 NA
8a A8a SB4 1 2,700 NA
8a A8a SB5 1 2,130 NA
8a A8a SB6 1 1,240 NA
8a S11 0.25 300
130 (WET)
0.56(TCLP)
A12 A12 SB1 1 3,980 NA
A12 A12 SB5 1 1,050 NA
8a A8a SB2 1 850 2.5 78.7 3,790 NA
8c A8c SB2 1 850 2.5 78.7 1,220 NA
8e NS1 0.25 850 2.5 78.7 680 47 (WET)
8e S1 0.25 850 2.5 78.7 480 21 (WET) ND(TCLP)
8h A8h SB7 1 850 2.5 78.7 2,320 NA
Total cy 1773.1
Abbreviations
cy = cubic yards
mg/kg = milligram per kilogram
TABLE 5. TARGETED LEAD EXCAVATIONS
Former Riverside Scrap Iron & Metal Property
Riverside, California
Remedial Action Plan
1111.12.512000
3750 2.5 347.2
GSI Job No. 6239
Off-Site Location
Original
Sample
Designation
Sample
Depth
(feet)
Approximate
Area (square
feet)
Approximate
Maxium
Excavation
Depth (feet)
Cubic
yards
Lead
(mg/kg)
Total PCBs
Identified
(mg/kg)
PAHs Identified
(Appendix A-2)
S1-0.25 0.25 183 none none
S8-0.25 0.25 95.5 none none
S9 0.25 0.25 153 none none
S12 0.25 0.25 86.1 none none
S14 0.25 0.25 78.4 none 4 PAHs
S19-0.25 0.25 121 none benzo(a)pyrene
S19 1 1 193 none none
S20 0.25 0.25 976 0.39 none
S22 0.25 0.25 89.9 none benzo(a)pyrene
S23 0.25 0.25 105 none benzo(a)pyrene
S24 0.25 0.25 36 none benzo(a)pyrene
Total cy 307
Abbreviations
PAHs = polycyclic aromatic hydrocarbons
PCBs = polycyclic biphenyls
none = no COCs were detected above the residential screening criteria (Table 3) cy = cubic yards
mg/kg = milligram per kilogram
Notes
Deeper samples were analyzed at all sample locations with COC concentrations detected above screening levels. Concentrations of COCs above screening levels were not detected at a depth greater than 0.25 feet bgs, with the exception of sample S19, where lead was detected at 1 foot, but not at
2.5 feet bgs.
2981 6th Street
Resdience
Samples S25 through S28 were collected at the Mission Inn Entry. No COCs above screening levels were identified.
Samples S1 through S40 were collected at off-Site locations. Only samples with concentrations of COCs exceeding residential screening criteria identified in Table 3 are listed here.
Samples S29 thorugh S33 were collected at the Riverside Scrap 5th Street Entry and will be included with the on-Site excavation.
Samples S34 through S40 were collected at the Riverside Scrap 6th Street Entry and will be included with the on-Site excavation. 1113000
Access was not granted to 2980 5th Street for sampling.
TABLE 6. TARGETED OFF-SITE EXCAVATIONS
Former Riverside Scrap Iron & Metal Property
Riverside, California
Remedial Action Plan
1 2981 Mission Inn
Residence 67
130
1800
3500
1 12968 6th Street
GSI Job No. 6239
Constituents
Confirmation
Sample Node
(Figure 7)
Sample
Location
Maximum
Depth
Detected
Constituents
Confirmation
Sample Node
(Figure 7)
Sample
Location
Maximum
Depth
Detected
Constituents
Confirmation
Sample Node
(Figure 6)
Sample
Location
Maximum
Depth
Detected
PAH, Metals 3'1, 3'2 A8f-SB1 1 PAH, Metals, PCBs 11'8, 11'1 A10b-SB2 1 Metals 15'1, 15'2 A8g-SB1 1 PAH, Metals 4'2, 4'2 A8f-SB2 1 PAH, Metals, PCBs 12'8, 12'1 A10b-SB3 1 Metals 17'1, 17'2 A8g-SB2 1 PAH, Metals, PCBs1 6'1, 6'2 A8f-SB3 1 Metals 12'7, 12'8 A10b-SB4 1 PAH, Metals 18'1, 18'2 A8g-SB3 1 Metals 3'1, 3'2 NS3 3 PAH, Metals 12'8, 12'1 S14 1
Metals 2'1, 2'2 S3 2.5 PCBs 10'8, 13'1 NS13 2.5 PAHs, PCBs, TPH 16'4 NS20 5 PCBs 14'4, 15'4 ES3 0.25
Metals, PCBs 2'2, 2'3 A8e-SB1 1 Metals, PCBs 9'1, 9'2 A12-SB1 1 PCBs 15'5, 16'5 NS18 0.25 Metals 3'2, 3'3 A8e-SB2 1 PAH, Metals 10'1, 10'2 A12-SB2 1 PAH, Metals, PCBs 15'4, 15'5 A8h-SB2 1 PAH, Metals 5'2, 5'3 A8e-SB3 1 PAH, Metals 11'1, 11'2 A12-SB3 1 PAH, Metals, PCBs 16'3, 16'4 A8h-SB3 1 Metals PCB Area 4 A8e-SB4 1 PAH, Metals, PCBs 12'1, 12'2 A12-SB4 1 PAH, Metals, PCBs 17'3, 17'4 A8h-SB4 1 Metals, PCBs 4'4, 4'5 A8e-SB6 1 Metals, PCBs 13'1 A12-SB5 1 Metals 19'2, 19'3 A8h-SB6 1 Metals 4'4, 4'5 A8e-SB7 1 PCBs 10'1, 10'2 S10 1 PAH, Metals, PCBs 17'2, 17'3 A8h-SB7 1 Metals 6'3, 6'4 A8e-SB8 1 PAH, Metals, PCBs 15'2, 15'3 A8h-SB8 1 Metals 1'3, 1'4 NS1 0.25 Metals, PCBs 9'5, 9'6 A8a-SB1 1 Metals 1'2, 1'3 S1 0.25 PAH, Metals, PCBs 10'5, 10'6 A8a-SB2 1 Metals, PCBs 5'2, S5 0.25 Metals, PCBs 9'2, 9'3 A8a-SB3 1 Metals, PCBs 13'9, 13'10 S29 0.25 0.25 Metals 12'3, 12'4 A8a-SB4 1 Metals, PAH 14'1, 14'2 S30 0.25 0.25 PCBs, Metals 3'5, 3'6 A8d-SB2 1 PAH, Metals, PCBs 10'2, 10'3 A8a-SB5 1 Metals, PAH, PCBs 14'3, 14'4 S31 0.25 0.25 PCBs, Metals 5'5, 5'6 A8d-SB3 1 PAH, Metals, PCBs 11'2, 11'3 A8a-SB6 1 PCBs 6'5, 6'6 A8d-SB4 1 PCBs 10'2, 10'3 NS7 2.5 Notes:
PAH, PCBs 2'5, 2'6 NS2 0.25 PCBs 10'5, 10'6 NS8 0.25
PCBs 4'5, 4'6 NS25 0.25 PCBs 11'5, 11'6 NS28 0.25
PCBs 5'5, 5'6 NS26 0.25 TPH 9'2, 9'3 S8 5
PCBs 3'5, 3'6 S4 0.25 PCBs 9'5, 9'6 S9 0.25
Metals 10'3, 10'4 S11 0.25
Metals 10'5, 10'6 S12 2.5
Metals, PCBs2 MIR'1 through 4 S1 0.25 0.25 PCBs 12'3, 12'4 S 13 0.25 Metals, PCBs2 MIR'5 through 8 S8 0.25 0.25
Metals, PCBs 13'4 A8b-SB1 1
Metals, PCBs 13'3, 13'4 A8b-SB3 1
Metals V6'1 through 4 S12
‐
0.25 0.25 Metals, PCBs 13'2, 13'3 A8b-SB4 1
Metals and PAH V6'5 through 8 S14-0.25 0.25 Metals, PCBs 12'3, 13'3 ES2 0.25 Metals V6'9 through 12 S9
‐
0.25 0.25
Metals 12'5, 12'6 A8c-SB1 1
Metals, PCBs 12'4, 13'4 A8c-SB2 1
Metals, PCBs 7'5, 7'6 S34
‐
0.25 0.25 Metals, PCBs 11'5, 12'5 A8c-SB3 1
Metals, PCBs 7'5, 7'6 S35
‐
0.25 0.25 PAH, Metals 12'5,12'6 A8c-SB4 1
Metals, PAH, PCBs 7'4, 7'5 S37
‐
0.25 0.25 PCBs 11'4, 11'5 NS10A 0.25
Metals, PAH, PCBs 7'3, 7'4 S38
‐
0.25 0.25 PCBs 12'6, 13'6 NS29 0.25
Metals 7'2, 7'3 S39
‐
0.25 0.25 PCBs 13'5, 13'6 NS15 0.25
Metals, PAH, PCBs 7'1, 8'1 S40
‐
0.25 0.25 PCBs 12'5, 12'6 S15 0.25
PAH 7'1, 8'1 S40
‐
1 1
Metals and PAH 6R'1, 6R'2 S19 0.25 0.25
Metals 6R'1, 6R'2 S19
‐
1 1
Metals, PCBs 6R'3, 6R'4 S20-0.25 0.25
Metals and PAH 6R'5, 6R'6 S22
‐
0.25 0.25
Metals and PAH 6R'7, 6R'8 S23
‐
0.25 0.25
PAH 6R'9, 6R10 S24
‐
0.25 0.25
Off-Site - 2981 6th Street Residence
Off-Site - 2981 Mission Inn Residence
6th Street Entry
Area 8c
Area 8d
Off-Site - 2968 6th Street Vacant Lot
Area 8b
Area 8e
Area 8f
1) Locations included in this table with PCB detections are >0.17 and <50mg/kg.
Concentrations equal to or over 50 mg/kg and surrounding confirmation sample locations will be excavated during the TSCA excavation.
TABLE 7. CONSTITUENTS EXCEEDING RSLs
Remedial Action Plan
Former Riverside Scrap Iron & Metal Property
Riverside, California
2) Locations did not report PCBs above the residential RSL. However, PCB Area 6 excavation is located adjacent to this area on the Site, so confirmation samples for PCBs will be collected.
5th Street Entry
Area 12
Area 10b
Area 8a
Area 8g
Area 8h
GSI Job No.: 6239
Former Riverside Scrap Iron & Metal Property Response Plan
FIGURES
Figure 1. Site Location Map
Figure 2. Site Map
Figure 3. Pre-Delineation Sampling Distribution of PCBs in Soil Figure 4A. Post-Delineation Sampling Distribution of PCBs in Soil – Northern Areas Figure 4B. Post-Delineation Sampling Distribution of PCBs in Soil – Southern Areas Figure 4C. Proposed Target Lead Excavations
Figure 5. Proposed On-Site Excavation Plan
Figure 6A. Proposed Off‐Site Excavations – Northern Areas Figure 6B. Proposed Off‐Site Excavations – Southern Areas Figure 7. Proposed Confirmation Sampling Grid
GSI Job No.
Issued:
Revised:
Map ID:
Drawn by:
Chk'd by:
Aprv'd by:
0 1.5 30.75
Miles
FIGURE 1
6239
RS6239_SLM
6-Feb-2023
AV
SC SITE LOCATION MAP
Former Riverside Scrap Iron & Metal Property
Riverside, California
TFW
£
Reference map provided by Esri, 2022.
SITE
LOCATION
^_
^_
CaliforniaCalifornia
Drawn By:
Chk'd By:
Appv'd By:Map ID:
Issued:
GSI Job No.
MISSION INN AVENUE
6TH STREET 5TH STREET
COMMERCE STREET
Historical
Building
Parking
Lot
Materials Storage
Residential Residential Residential
Maintenance
Yard
Office Maintenance
Yard
Main Office
Covered
Shed
Recyclable
Materials
Public Drop-off
Recyclable Materials Storage
Scrap Storage
8f
8e
8d
10a
10b
12 8a
8b
8c
8h
8g
4TH STREET
13 3RD STREET
Projected Coordinate System
Datum: NAD83
State Plane California Zone VI
Units: Feet
SITE MAP
6239 AV
6-Feb-2023
RS6239_SiteMap
0 14070
SCALE (Feet)
SC
SC
Former Riverside Scrap Iron & Metal Site
Riverside, California
Area Designation Border
Site Boundary
q
LEGEND
FIGURE 2
Site Area Designation (Geomatrix, 2005)
Basemap downloaded from Google Earth Pro dated
October 2016.
Note
8h
Projected Coordinate System
Datum: NAD83
State Plane California Zone VI
Units: Feet
PRE-DELINEATION SAMPLING
DISTRIBUTION OF PCBs IN SOIL
6239 AV
6-Feb-2023
RS6239_PreDelPCBs
0 13065
SCALE (Feet)
SC
SC
Former Riverside Scrap Iron & Metal Site
Riverside, California
Site Boundary
q
LEGEND
FIGURE 3
Soil Sampling Location (Amec, 2015)
Soil/Soil Gas Sampling Locations
(Amec, 2015)
Soil Sampling Locaton (AAA, 2011)
Off-Site Sampling Locations (Hillmann, 2017)
1) Figure provided by Hillmann Consulting, "Draft Remedial Action Plan", Figure 5A, 8 May, 2017.
2) Maximum PCB Concentrations shown in mg/kg.
3) Concentration >50 mg/kg shown in red.
Notes
!(
"
!
#
Drawn By:
Chk'd By:
Appv'd By:Map ID:
Issued:
GSI Job No.