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34 E Santa Clara St - 2024 - Soils management
SOIL MANAGEMENT PLAN ALEXAN ARCADIA PROJECT 34 EAST SANTA CLARA STREET ARCADIA, CALIFORNIA APNS# 5773-006-004, -005, -010, & -036 Prepared For: Arcadia Apartments, L.L.C. 5790 Fleet Street, Suite 140 Carlsbad, California 92008 Prepared by: FREY Environmental, Inc. 2817A Lafayette Avenue Newport Beach, California 92663-3715 (949) 723-1645 freyinc@freyinc.com Project No.: 698-24 April 7, 2023 (Updated July 26, 2023) Page | ii TABLE OF CONTENTS SECTION TITLE PAGE 1.0 INTRODUCTION 1 1.1 PURPOSE AND SCOPE 1 1.2 POTENTIAL CHEMICAL CONSTITUENTS OF CONCERN IN SOIL 1 2.0 SITE SETTING AND ENVIRONMENTAL BACKGROUND 2 2.1 SITE DESCRIPTION 2 2.2 HISTORICAL LAND USE 3 2.3 PAST ENVIRONMENTAL ASSESSMENTS 3 2.3.1 Phase I Assessment 3 2.3.2 Subsurface Soil and Soil Vapor Assessment 4 2.4 GROUNDWATER 6 3.0 PROPOSED SITE REDEVELOPMENT 6 4.0 SOIL MANAGEMENT PLAN 6 4.1 WASTE CHARACTERIZATION 6 4.2 GENERAL HANDLING OF POTENTIALLY IMPACTED SOIL 7 5.0 SITE CONTROL MEASURES 7 5.1 EXCLUSION ZONE 8 5.2 SUPPORT ZONE 8 5.3 PERSONAL HYGIENE AND GENERAL SAFETY REQUIREMENTS 8 5.3 CONFINED SPACE ENTRY REQUIREMENTS 8 6.0 MANAGEMENT OF SOILS AT THE SITE 8 6.1 SOIL EXCAVATION PARAMETERS 8 6.2 SOIL SCREENING AND SEGREGATION 9 6.2.1 Soil Screening Methods 9 6.2.2 Soil Stockpile Segregation 9 6.2.3 Excavation Confirmatory Field Screening 10 6.3 SOIL STOCKPILE CONSTRUCTION 10 6.4 DUST AND VAPOR CONTROL MITIGATION AND STORM WATER MANAGEMENT 11 6.5 SOIL STOCKPILE SAMPLING 12 6.5.1 Soil Sampling Methodology 12 6.5.2 Soil Sampling 12 6.5.3 Decontamination Procedures 13 6.5.4 Sample Transport and Laboratory Analyses of Soil Samples 13 Page | iii TABLE OF CONTENTS (Continued) SECTION TITLE PAGE 7.0 COC IMPACTED SOIL LOADING, TRANSPORTATION, AND OFF-SITE DISPOSAL 13 7.1 SOIL LOADING 13 7.2 TRANSPORTATION 14 7.3 SOIL DISPOSAL 14 8.0 MANAGEMENT AND QUALIFICATIONS 15 9.0 REPORTING 15 10.0 LIMITATIONS 16 REFERENCES 17 LIST OF TABLES TABLE 1 CHEMICAL ANALYSES OF SOIL SAMPLES – TPH & DETECTED VOCS TABLE 2 SUMMARY OF SOIL SAMPLE LABORATORY ANALYTICAL RESULTS – METALS TABLE 3 SUMMARY OF SOIL VAPOR SAMPLE LABORATORY RESULTS – DETECTED VOCS LIST OF FIGURES FIGURE 1 SITE LOCATION MAP FIGURE 2 AERIAL PHOTO SHOWING SOIL BORING AND VAPOR PROBE LOCATIONS LIST OF APPENDICES APPENDIX A ROUGH GRADING PLAN APPENDIX C SCAQMD VARIOUS LOCATIONS RULE 1166 PERMIT APPENDIX B SITE-SPECIFIC HEALTH AND SAFETY PLAN 1.0 INTRODUCTION This Soil Management Plan (SMP) describes the setting, subsurface environmental conditions, and presents a plan to manage excavated soils during redevelopment of the Alexan Arcadia Project located on 34 East Santa Clara Street in Arcadia, California (Site) (Figure 1). The Alexan Arcadia Project includes the redevelopment of the following Assessor’s Parcel Numbers (APNs) 5773-006-010 (30 E Santa Clara St), 5773-006-004 (25 Wheeler Ave), and 5773-006-005 (33 Wheeler Ave) (Figure 2). The Alexan Arcadia Project also includes the redevelopment of a portion of APN 5773-006-036 which is currently paved parking (Figure 2). Current addresses associated with this parcel are 150 & 180 North Santa Anita Avenue, and buildings at these addresses are not part of the current redevelopment plans. The Site, which is comprised of an approximate total of 2.5 acres, is proposed to be re-developed with a multi-level mixed-use, residential/commercial development with a subterranean parking structure. 1.1 PURPOSE AND SCOPE This SMP is designed to assist the Site owner with guidelines to identify potential or known environmental conditions that may be encountered during excavation activities associated with the Site redevelopment project to ensure compliance with applicable laws and regulations. This SMP will assist in achieving best practice environmental management for the excavation, management and disposal and/or re-use of soil during Site redevelopment. 1.2 POTENTIAL CHEMICALS OF CONCERN IN SOIL Though prior soil testing did not identify chemicals of concern (COCs) above residential screening levels in soil (Tables 1 and 2), COCs detected in some of the 1-foot and 5-foot bgs soil samples [total petroleum hydrocarbons (TPH)] indicate that soils in the upper 5 feet beneath some areas of the Site profile as regulated non-hazardous waste with respect to transportation and off-Site disposal (FREY, 2021). Additionally, volatile organic compounds (VOCs) is soil vapor [benzene and tetrachloroethylene (PCE)] were detected in one or more soil vapor samples collected and analyzed during prior soil vapor testing at the Site that exceeded at least one of the respective soil vapor screening levels (Table 3). As such, this SMP incorporates information regarding the management and handling of any soils that could contain petroleum hydrocarbons and VOCs. Additional information regarding the COCs evaluated at the Site is presented in Section 2.0. Page | 2 2.0 SITE SETTING AND ENVIRONMENTAL BACKGROUND 2.1 SITE SETTING The Site, which covers approximately 2.5 acres, is located on the east side of North Santa Anita Avenue between East Santa Clara Street and Wheeler Avenue is configured as shown on Figure 2. The Site is located in a commercial/industrial area. The Site is bound to the north by East Santa Clara Street. Beyond Santa Clara Street is a parking lot to the northwest, a REI retail store and parking lot to the north, and a parking garage to the northeast. The Site is bound by an alley and a US Postal Service and parking lot further east beyond the alley. To the south, the Site is bound by Wheeler Avenue, and beyond Wheeler Avenue is an expansive parking lot for commercial properties located further to the south. To the southwest, the Site shares boundary with a property occupied by a dermatological office. The Site is bound to the west (from north to south) by a bank building (180 N Santa Anita Ave), a multi-story office building (150 N Santa Anita Ave), and a medical and personal service complex (100 N Santa Anita Ave). The Site is currently developed and occupied as follows (FREY, 2021a): APN 5773-006-036 This parcel is 2.18 acres occupied by an 8-story office building (150 N Santa Anita Ave) an approximate 8,616 sq/ft footprint and a single-story bank building (180 N Santa Anita Ave) with an approximate 6,534 square foot (sq/ft) building footprint. The rest of this parcel is mainly paved parking. The two buildings on this parcel are not part of the current Alexan Arcadia redevelopment project, and plans are to leave the two buildings in place. APN 5773-006-010 This parcel is 0.37-acre and developed with a two-story concrete, multi-tenant office building (30 E Santa Clara St) with an approximate 8,634 sq/ft building footprint. The remainder of the parcel in the rear of the building is paved parking. The building is occupied by multiple commercial office spaces including a software company office, hospice care offices, travel agency offices, home health care / health insurance offices, and a vacant office space. APN 5773-006-004 This parcel is 0.18-acre and currently developed with a single-story stucco and block commercial building (25 Wheeler Ave) with an approximate 4,591 sq/ft building footprint. The remainder of the parcel in the rear of the building is paved parking. This building was occupied by multiple small business office spaces including a CPA office, an alternative care office, an insurance office, a gift boutique, a security system office, and multiple vacant office spaces. Page | 3 APN 5773-006-005 This parcel is 0.18-acre and currently developed with a vacant, single-story stucco and block office building (33 Wheeler Ave) with an approximate 3,750 sq/ft building footprint. The remainder of the parcel in the rear of the building is paved parking. 2.2 HISTORICAL LAND USE Portions of the Site were developed as early as the 1920s for mixed residential and commercial use. Various phase of development and redevelopment to the Site have occurred since the 1920s, with the Site mainly used for commercial/office purposes with the exception of a former industrial laundry and linen supplying business. The laundry business occupied a large building (formerly 122 North Santa Anita Avenue) formerly located on the southeast corner of North Santa Anita Ave and East Santa Clara Street between 1949 and 1966 in the location now occupied by the bank building (180 N Santa Anita Ave) (FREY, 2021a). 2.3 PAST ENVIRONMENTAL ASSESSMENTS 2.3.1 Phase I Assessment FREY performed a Phase I Environmental Site Assessment for the project Site which was documented in a report titled “Phase I Environmental Site Assessment”, dated April 26, 2021 (“Phase I ESA”) (FREY, 2021a). The Phase I ESA identified the following Recognized Environmental Conditions (RECs): On-Site Concerns An industrial laundry and linen business operated at the Site in a large building formerly occupying 122 North Santa Anita Avenue (current location of the bank building at 180 North Santa Anita Avenue) between 1949 and 1966. The business(es), identified as Model Laundry & Linen Supply Co, Peerless Linen Rental Service, and Pur-O-Serve Linen Supply, employed motor operated machinery. Solvents such as tetrachloroethylene (PCE) have commonly been used in the clothes cleaning process. PCE is a VOC regulated by local, state and federal governments. Details of the type of cleaning services offered by this facility were not identified in the Phase I ESA. Thus, the use of solvents by this former industrial laundry facility cannot be ruled out and was identified as a recognized environmental condition (REC) and a potential vapor encroachment condition (VEC). Page | 4 Off-Site Concerns Various properties near the Site, which use, have used, or have a high likelihood of using COCs were identified during the Phase I ESA (FREY, 2021a). The following properties were identified as having potential RECs and/or VECs based on the nature of the business(es) that occupied them, the regulatory database information reviewed for them, and proximity to the Site. Former Petroleum Hydrocarbon UST or AST Locations 214 N Santa Anita Ave (immediately north of the Site) – Arcadia Lumber Company 145-147 N Santa Anita Ave (immediately west of the Site) – Parking Lot 101 N Santa Anita Ave (immediately southwest of the Site) – Rusnak/Arcadia 23 Santa Clara St (immediately north of the Site) – Arcadia Lumber 21 W Santa Clara Street (immediately northwest of the Site) – Pac Bell Drycleaners and Potential Drycleaners (Solvent Concern) 149/151 N Santa Anita Ave (immediately west of the Site) – Oak View Cleaners 231 N 1st St (515 ft northeast of Site) – Your Valet Cleaners 104 N 1st Ave (525 ft east of Site) – Half Hour Laundry 408 N Santa Anita Ave (870 feet north-northwest of Site) – Town Cleaners Large Quantity Hazardous Materials Generator (Solvent Concern) 44 La Porte St (765 feet north-northeast of the Site) – Danco Metal Surfacing / Anodizing (A clean up case was closed for this facility in 1997. However, the facility is a large quantity generator of hazardous waste such as liquids with heavy metals and oxygenated solvents as reported from 1996 through 2019.) 2.3.2 Subsurface Soil and Soil Vapor Assessment In June, 2021, FREY performed a subsurface soil and soil vapor investigation that was documented in a report dated July 22, 2021 (FREY, 2021b). The investigation included the collection of soil samples from 7 locations (B1, B2, and MP1 through MP5) at depths of 1 foot below ground surface (bgs) and at 5-foot depth intervals from approximately 5-feet bgs to the bottom of each boring (15 feet bgs), and the collection of soil vapor samples from dual-nested vapor probes MP1 though MP5. Sampling locations are depicted on Figure 2. The soil samples collected at 1, 5, 10 and 15 feet bgs from borings B1, B2, MP4 and MP5 were analyzed for TPH with a carbon chain breakdown, VOCs, and Title 22 metals. The soil samples collected at 5, 10 and 15 feet bgs from borings MP4 and MP5 were analyzed for VOCs. With the exception of the 15-foot soil vapor probe in MP3 (which was not sampled due to a lack of vapor flow), soil vapor samples collected from both the 5- and 15-foot bgs intervals of probes MP1 through MP5 were analyzed for VOCs. Page | 5 The following is a brief summary of the results and conclusions of the investigation: Subsurface soils encountered consisted primarily of fine to coarse sands and fine silty sands to depths to maximum depths explored of 15 feet below ground surface (bgs), with some sandy silt encountered at approximately 14 feet bgs in one location. Groundwater was not encountered during the investigation. TPH were detected in the 1-foot bgs soil samples collected and analyzed from four of the borings and in the 5-foot bgs soil samples collected and analyzed from two borings. TPH were not detected in any of the other soil samples collected and analyzed for TPH. TPH detected in the soil samples collected and analyzed during this investigation did not exceed applicable human health screening levels for a residential setting (Table 1). Acetone, benzene, PCE and toluene were the only VOCs detected in the soil samples collected and analyzed for VOCs. VOCs detected in the soil samples collected and analyzed during this investigation did not exceed applicable human health screening levels for a residential setting (Table 1). Various metals were detected in the soil samples collected and analyzed during this investigation at relatively low concentrations that did not exceed applicable human health screening levels for a residential setting (Table 2). Based on the soil sample analytical results for TPH, VOCs and metals, the sampled soils do not profile as State (non-RCRA) or Federal (RCRA) hazardous waste. However, the TPH concentrations detected in some of the 1-foot and 5-foot bgs soil samples indicate that soils in the upper 5 feet beneath some areas of the Site profile as regulated non- hazardous waste with respect to transportation and off-Site disposal. Detected VOCs in soil vapor samples that exceeded at least one human health screening level based on a residential land use setting included benzene (15-foot probe in MP5), and PCE (all probes). Other VOCs were either not detected or detected at relatively low concentrations below regulatory screening levels based on a residential land use (Table 3). Due to the concentrations of VOCs, particularly PCE, detected in soil vapor across the Site it was recommended that any future residential buildings with slab on-grade construction should be constructed with soil vapor intrusion mitigation systems (e.g. – sub-slab vapor barrier). (Note: It has since been decided that all future residences will be built above the future subterranean parking structure.) Page | 6 2.4 GROUNDWATER Groundwater was not encountered to a depth of 15 feet bgs during Site assessment work conducted in June 2021 (FREY, 2021b). Based on information presented in the Phase I ESA report, first-encountered groundwater occurs at approximately 295 feet bgs in the Site area (FREY, 2021). Groundwater is not anticipated to be encountered during the subject re- development project. 3.0 PROPOSED SITE REDEVELOPMENT The Site is proposed to be re-developed with a multi-level mixed-use, residential/commercial development that will have two levels of subterranean parking. Site preparation will include removal of any refuse and recyclable materials. The existing structures will be demolished, and the pavement removed prior to grading. The proposed grading plan includes excavating the majority of the Site to depths of up to approximately 25 feet bgs to accommodate the subterranean parking structure. As indicated on the rough grading plan in Appendix A, approximately 65,200 cubic yards of cut for export and 100 cubic yards of fill are estimated to be required to complete rough grade pad elevations. Any imported fill material will be properly characterized in accordance with the DTSC Information Advisory for Clean Imported Fill Material. 4.0 SOIL MANAGEMENT PLAN The primary purpose of this SMP is to assist the general contractor and subcontractors, generally referred to in this document as the Contractor, in decision making regarding soil handling and to prevent accidents which may result in personal injury or property damage. It is important to recognize that the procedures contained herein cannot cover all situations. They do not relieve the Contractor of its responsibility to use good judgment at all times. Soil removal, transportation, and disposal activities will be performed in general accordance with applicable federal, state, and local laws, regulations, and ordinances, including the Occupational Safety and Health Act (OSHA). On-site contractors and transportation contractors, who are responsible for completing the excavation and removal activities, should be provided a copy of this SMP. 4.1 WASTE CHARACTERIZATION Based on previous subsurface investigative work conducted at the Site: An unknown quantity of soil with relatively low petroleum hydrocarbon concentrations (non-hazardous, not regulated) will be excavated and transported to a yet to be designated Class III landfill that will accept them for disposal, or to Soil Safe, Inc. in Adelanto, California, for recycling, and; Page | 7 An unknown quantity of soil with relatively low concentrations of PCE/TCE (non-hazardous, not regulated) may be encountered. If encountered, they will be excavated and transported to a yet to be designated Class III landfill for disposal. 4.2 GENERAL HANDLING OF POTENTIALLY IMPACTED SOIL Soils generated during grading and excavation work for the Site redevelopment project will be monitored for the presence of COCs in accordance with South Coast Air Quality Management District (SCAQMD) Rule 1166. A SCAQMD Rule 1166 Permit is attached in Appendix B. All requirements stipulated in the SCAQMD Rule 1166 Permit must be met for the subject project and shall take precedent over any potentially conflicting requirements given in this SMP. Excavation activities involving soil impacted or potentially impacted with TPH and/or VOCs shall be performed by a grading contractor in accordance with South Coast Air Quality Management District (SCAQMD) requirements, rules, and permits as applicable. VOCs will be monitored by environmental field personnel using a photoionization detector (PID). Required personal protective devices must be made immediately available onsite in accordance with the Health and Safety Plan (HASP) included in Appendix C. Consistent with OSHA's 29 CFR 1910.120 regulation covering Hazardous Waste Operations and Emergency Response (HAZWOPER), all Site personnel who will be supervising or performing a hazardous or a potentially hazardous activity involving exposure to potentially toxic materials, are required to be trained in accordance with the standard. All personnel working on Site will receive a Site-specific training session prior to commencing work at the Site. Daily "tailgate" safety meetings are also to be conducted to review accomplishments of the previous day, clarify any newly-identified concerns, and describe the work to be done that day. Copies of all training certificates will be kept at the on-site job trailer. Each worker should have practical experience in the operation of the types of on-Site fire extinguishers. All workers are to have stop-work authority: anyone observing an unsafe condition or an unsafe act is to order all work to stop until the situation is rectified. 5.0 SITE CONTROL MEASURES This section outlines the Site control measures to be implemented during Site redevelopment. Listed below are the work zones that shall be established when soils with potential COCs are encountered at the Site. The zone boundaries may be modified as necessary as new information becomes available. Changes to the exclusion zone will be communicated daily, during the Site tailgate safety meeting. Additional details are provided in the HASP in Appendix C. Page | 8 5.1 EXCLUSION ZONE The Exclusion Zone is where there will be direct contact with potentially COC impacted soil. The level of personal protective equipment (PPE) required shall be based on the specific hazard and existing Site conditions. The boundary of the Exclusion Zone may be defined with delineators, caution tape, barricades, and/or signage. Modification to the size and boundary of the Exclusion Zone will be made in the field at the time, based on the scope of work and the Project Manager’s discretion. 5.2 SUPPORT ZONE In the Support Zone, areas are to be set aside for eating and resting. The Support Zone may be used as a storage area for operations equipment, and air monitoring will also be feasible from the Support Zone. 5.3 PERSONAL HYGIENE AND GENERAL SAFETY REQUIREMENTS Within the Exclusion Zone, personnel supervising or performing work that may be subject to exposures to COCs vapors or soil shall observe and strictly adhere to the provisions of the HASP. Any personnel found disregarding the provisions of the HSP will be barred from the Site. Personal protective equipment (PPE) must be utilized by on-Site personnel when deemed necessary. Each individual will be responsible for the proper inspection, maintenance and fit of his or her PPE prior to entering the Exclusion Zone. Hard hats and safety glasses with side shields will be worn on-Site at all times. No open flames or smoking will be permitted in the Exclusion Zone. Should respirators be required, personnel donning the respirators shall not have facial hair which prevents effective use of the respirator. 5.4 CONFINED SPACE ENTRY REQUIREMENTS In trenching that is five feet deep or deeper, the excavation must be appropriately shored or sloped. If workers are required to enter an excavation that is five feet deep or greater that is not shored or sloped, a permit from the Division of Occupational Safety and Health, California Department of Industrial Relations must be obtained before excavating and the appropriate OSHA confined space requirements must be followed. 6.0 MANAGEMENT OF SOILS AT THE SITE 6.1 SOIL EXCAVATION PARAMETERS The disturbed soil area for the project is approximately 2.5 acres. Excavated soils and materials will be observed for the potential presence of COCs. Page | 9 Handling, storing, transporting and disposing of COC impacted soils are subject to State and local regulations depending upon whether soils are considered hazardous or non-hazardous as described in CCR Title 22. The determination as to whether the impacted soil is hazardous is based on the following hazardous waste characteristics: ignitability, corrosivity, reactivity and toxicity. Based on the results of the previous investigation conducted at the Site in 2021, it is highly unlikely that any COC impacted soils encountered will exhibit any of these four characteristics based on the nature of the contaminants, concentrations of the contaminants, and/or the buffering/neutralizing nature of soil. Regardless of whether the soil in question is hazardous or non-hazardous, waste manifest records should be maintained regarding its transportation and disposal. In addition, the contractor should implement appropriate health and safety procedures to prevent or minimize potential exposure of impacted soil to workers, the surrounding community and the environment. Workers should conduct their activities in accordance with State rules as outlined in the HASP. 6.2 SOIL SCREENING AND SEGREGATION 6.2.1 Soil Screening Methods Should soils containing COCs be encountered during excavation activities, concentrations of undifferentiated volatile organic compounds (UVOCs) will be screened in the field using a hand- held PID. Personnel trained in the operation, calibration and application of the manufacturer’s methods for PID use will be allowed to conduct soil screening. The PID must be calibrated daily in accordance with the manufacturer’s procedures and protocol. Field methods and calibration documentation must be recorded and will be submitted as part of a final summary report discussed in Section 9.0. 6.2.2 Soil Stockpile Segregation Should soils excavated during the project be found to contain potential COC constituents, excavated soils should then be separated into two or more stockpiles based upon visual, olfactory and PID monitoring. Soils which exhibit evidence of visual or olfactory impact and/or exhibit a PID reading in excess of 50 parts per million by volume (ppmv) will be stockpiled in an area designated for said soils. Soil stockpile sizes will be kept to a manageable size of less than 400 cubic yards as per SCAQMD Rule 1166 permit requirements. Soils which exhibit PID readings in excess of 50 ppmv will be stockpiled in the area designated for impacted soils. No more than a total of 2,000 cubic yards of such soils, which the SCAQMD classifies as “VOCs contaminated,” shall be excavated and removed from the Site under the Various Locations SCAQMD permit planned to be used for the subject project (Appendix A). Should more than 2,000 cubic yards of VOC impacted soil be encountered, then a Site-specific SCAQMD Rule 1166 permit will need to be obtained. Page | 10 Based on the prior subsurface investigation conducted at the Site, it is not anticipated that PID readings of 1,000 ppmv or greater will be observed during excavation at the subject project. However, in the event such readings are encountered, refer to the Rule 1166 Permit in Appendix A for procedures and protocol regarding handling of soils with UVOC readings greater than 1,000 ppmv. 6.2.3 Excavation Confirmatory Field Screening Should COC impacted soils remain following excavation activities, excavation confirmation soil screening will be completed upon completion of excavation activities. Field personnel shall not enter any excavation that is greater than 4 feet in depth unless properly sloped and/or shored. Field personnel shall screen sidewall soils by placing the PID approximately 3 inches from the exposed soil surface at approximate 50-foot intervals around the entire excavation. Soils which comprise the excavation bottom will be screened in a similar fashion with field personnel traversing the excavation following an approximate 50-foot grid pattern. Soil screening locations which exhibit greater than 50 ppm on the PID, and/or are discolored or malodorous will be plotted on a map. 6.3 SOIL STOCKPILE CONSTRUCTION Any suspected COC impacted soil stockpiles will be placed on 6-millimeter-thick plastic sheeting. Any VOCs impacted soil stockpiles must be covered with 6-millimeter-thick plastic sheeting. Seams in the plastic sheeting must overlap a minimum of 24 inches. Sandbags or other appropriate weighting objects must be placed on the overlapping seams to secure the sheeting in place. The working face of the potentially impacted stockpile will be moistened with water during periods of inactivity which exceed one day. At the end of each work day, all stockpiles shall be completely covered and securely anchored to prevent any exposure of soil to the atmosphere. Erosion controls (fiber roll, rock berms, etc.) must be installed and maintained around all soil piles. Controls must be inspected by the contractor each working day. Erosion controls in need of repair or replacement must be conducted within 24 hours of discovery. All soil stockpiles must be located a minimum of 20 feet from a storm water surface drain. Soil stockpiles must have identification markers which correspond to where the soil originated from in the excavation. The boundaries of each soil stockpile will be recorded. Soil stockpiles are anticipated to be no larger than 100 cubic yards in size. All stockpiles must be inspected daily and the inspection findings recorded on a stockpile inspection log in accordance with SCAQMD Rule 1166 permit requirements. Page | 11 6.4 DUST AND VAPOR MITIGATION AND STORM WATER MANAGEMENT Storm management methods and strategies to reduce uncontrolled spreading of sediments and pollutants to off-Site areas during wind gusts and storm events will be implemented. Proper temporary storage of any hazardous materials will be implemented. Best Management Practices (BMPs) will be applied to stockpiles to reduce the potential of sediment being spread by wind gusts and storm events. In addition, hazardous waste management activities shall be performed as outlined in the California Stormwater Quality Association BMP Handbook. Dust and vapor emissions shall be controlled during the project such that no noticeable dust or odor is observable outside the controlled work area. The Site area will be surrounded with fencing that is a minimum of 6 feet tall, with a windscreen with a porosity of 50 ± 5%. During Site grading, soils will be adequately wetted to the depth of earth-moving activity with adequate time allowed for penetration. Soils will be wet at sufficient frequencies to prevent the generation of visible dust plumes. Moving vehicles on, within, or off the Site when earthmoving activities are occurring shall: 1) post signs at all entrances of the Site to designate the speed limit as 15 miles per hour; 2) stabilize the surface of all vehicular traffic and parking areas by applying gravel, paving, or dust suppressant; 3) Not allow track-out to extend beyond 25 feet of the property line and remove any track-out each day using a vacuum equipped with a filter(s) rated by the manufacturer to achieve a 99.97% capture efficiency for 0.3 micron particles; 4) clean the soil from the exterior of trucks, trailers, and tires prior to the truck leaving the Site; and 5) utilize at least one of the measures listed below at each vehicle egress from the Site to a paved public road: Install a pad consisting of washed gravel (minimum-size: one inch), maintained in a clean condition, to a depth of at least six inches and extending at least 30 feet wide and at least 50 feet long; Utilize a wheel shaker/wheel spreading device consisting of raised dividers (rails, pipes, or grates) at least 24 feet long and 10 feet wide; or, Install and utilize a wheel washing system to remove soil from tires and vehicle undercarriages. Dust and vapor control measures shall be implemented during construction to minimize dust/odor emissions. Dust suppression may be performed by actively spraying water on construction debris and exposed soil during handling, separating and loading. Additional dust control measures may include: using a perimeter misting system, covering waste within the excavation and on stockpiles, covering non-active stockpiles with plastic sheeting, and temporarily suspending dust-generating activities until the problem has been resolved. Equipment and vehicles used to load and move soil will be operated at speeds that minimize generation of airborne particles. The distance soil is dropped onto stockpiles and into containers will be minimized. Soil transfer will be conducted on the leeward side of trucks/stockpiles to reduce the potential for wind to generate particulates. Page | 12 Soil stockpiles will be placed and shaped to minimize generation of particles from wind if feasible. Soil disturbance and loading activities will be halted and the work areas secured if wind speeds exceed 25 miles per hour. Soil stockpiles will be placed on and covered with plastic sheeting. The plastic sheeting covering the stockpiles will be secured with sandbags or equivalent. 6.5 SOIL STOCKPILE SAMPLING 6.5.1 Soil Sampling Methodology Personnel collecting soil samples for submittal to the laboratory will put on unused latex gloves prior to the collection of each sample. A 1-foot by 1-foot square area will be dug 1-foot deep into the surficial soils to designate the sample collection area. Soil samples will be collected by inserting a trowel directly into the freshly exposed soil surface. The extracted soil will be directly transferred into a laboratory supplied, 4-ounce, screw top, glass jar. The trowel will be used to fill the glass jar to maximum capacity. A sheet of Teflon sheeting will be placed over the open end of the sample jar. The cap will be screwed onto the jar until tight. Each sample will be labeled with a sample specific identification (for example Area 1, Sample 1), time and date, and soil sampler’s name. The use of new gloves, sample jars and Teflon tape for the collection of each sample will minimize the potential for cross-contamination. Equipment that will be reused must be decontaminated with triple rinse and non-phosphate detergent using de-ionized water for the last rinse. The samples will then be placed in a chest cooled with ice as discussed in greater detail in Section 6.5.4. 6.5.2 Soil Sampling Soils classified as potentially COC impacted may be sampled at the following frequencies if they exhibit indications that the soil impacts are different than those encountered during previous subsurface investigative work: Stockpiles containing up to 400 cubic yards (maximum size allowed under SCAQMD Rule 1166 permit): collect a minimum of one soil sample per 25 cubic yards or portion thereof (for example, a 130 cubic yard stockpile will require 6 soil samples). The stockpile will be divided into 25 cubic yard portions and a minimum of one sample will be obtained from each 25 cubic yard portion. Sample locations will be randomly selected within each 25 cubic yard portion of the stockpile. Collected soil samples may be submitted for laboratory analysis as discussed in Section 6.5.4 to allow for additional characterization and profiling of soils for off-Site disposal, if required. Soil sample collection depths within the soil stockpile should not be collected from depths less than 12 inches from the exposed surface of the stockpile. Page | 13 6.5.3 Decontamination Procedures The soil sampling methodology has been designed to minimize, if not eliminate, the potential for cross-contamination. Tools used as part of the soil sampling process that are not disposable/dedicated for each sample location will be cleaned between sample intervals using a triple rinse consisting of: a brush and tap water rinse, followed by a brush and a non-phosphate-TSP solution rinse, followed by de-ionized water rinse. The decontamination station will be placed upwind of all sampling areas. 6.5.4 Sample Transport and Laboratory Analyses of Soil Samples After collection and labeling, each soil sample will be placed in an ice chest packed with ice and cooled to a maximum of 4 degrees Celsius and delivered to the laboratory. At the end of each work day, the cooler will be transported to the laboratory using chain of custody protocol. Soil samples will be analyzed by a State of California certified hazardous waste testing laboratory. Soil samples may be analyzed for at least one of the following parameters: TPH-full carbon chain breakdown by EPA Method No. 8015B(M). The breakdown ranges are typically C4 to C12 (gasoline); C10 to C22 (diesel); C22 to C44 (heavy end oil). The detection limit for each carbon range for soil will be 10 mg/kg. The holding time is 14 days for preserved samples. The holding time is seven days for unpreserved samples. VOCs by EPA Method No. 8260B. The detection limits range from 0.001 mg/kg to 0.050 mg/kg. The holding time for preserved soil samples (assuming extraction within 48 hours) is 14 days. The holding time is seven days for unpreserved samples. 7.0 COC IMPACTED SOIL LOADING, TRANSPORTATION, AND OFF-SITE DISPOSAL 7.1 SOIL LOADING The project manager will identify the correct stockpile and direct field personnel to remove the plastic sheeting from the area of the pile which will be the working face. The remainder of the pile will remain covered with sheeting until the working face migrates further into the pile and requires removal of sheeting. Water will be misted onto the working face, onto soils collected within the loader bucket and onto the soil as it is dumped into the end dump or truck and transfer. Once the end dump or truck and transfer is determined to be full, the truck driver will pull a tarp over the exposed soils and secure the tarp to the truck. Equipment and vehicles used to load and move soil will be operated at speeds that minimize the generation of airborne particles. In addition, the excavated areas and stockpiles will be wetted regularly to minimize the potential for dust. During soil transfer operations, the distance that soil is dropped into containers, stockpiles or trucks will be minimized. Soil transfer will take place on the leeward side of trucks and/or stockpiles to reduce the potential for wind to generate particles. Page | 14 Vehicles leaving the Site will be directed to drive over rumble strips prior to exiting the Site to remove soil from tires. 7.2 TRANSPORTATION Transportation of non-hazardous or hazardous wastes offsite will be in accordance with Department of Transportation (DOT) regulations contained in Code of Federal Regulations (CFR), Title 49 and the California Hazardous Waste Control Law (Health and Safety Code Section 25100 et seq.; California Code of Regulations (CCR), Title 22, Section 66428 et Seq.). Vehicle idling time within the staging areas will be kept to a minimum to limit air emissions. Hazardous waste haulers will have a valid Department of Toxic Substances Control (DTSC) registration and will satisfy the following requirements: Vehicles will have passed an annual inspection. Vehicle operators will be trained in the safe handling of the waste/material. Haulers will maintain the ability to pay damages caused by their operations through proper insurance coverage. Haulers will have licenses issued by the California Highway Patrol (CHP) for transportation of hazardous materials. Haulers will have an EPA identification number. Haulers will comply with the Uniform Hazardous Waste Manifest System. Haulers will take certain actions in response to hazardous waste discharges during transport (e.g., covering the load to prevent the discharge of dust/particulates into the atmosphere during hauling). 7.3 SOIL DISPOSAL COC impacted soil determined not suitable for reuse from the project shall not be disposed of at any other place outside of the Site property except at the facilities approved by the Site owner. COC impacted soil will be profiled, transported and disposed of under non-hazardous waste manifest to a State-licensed disposal or recycling facility. The contractor will complete and supply each truck with a non- hazardous waste manifest to be presented to the facility weigh master. Non-hazardous waste will be hauled by appropriately licensed and permitted transportation firms. Though not anticipated, should soils classified as California Hazardous Waste or as Resource Conservation and Recovery Act (RCRA) federal hazardous waste be encountered, they will be disposed of at appropriate disposal facilities as either California Hazardous Waste or as RCRA hazardous waste. Page | 15 8.0 MANAGEMENT AND QUALIFICATIONS The soil excavation and hauling aspect of this construction project will be managed by the General Contractor, AMPCO Contracting, Inc., and overseen by a State Registered Professional Engineer and/or Geologist from FREY Environmental, Inc. 9.0 REPORTING Daily, monthly and final summary reporting will be conducted for the project. The summary report will include, but not be limited to, a narrative of excavation activities, soil monitoring and screening activities and results, laboratory analyses and results, health and safety implementation, and documentation of final soil disposal/recycling/reuse. Supporting documentation will include, but not be limited to: Figures showing the Site location, excavation limits, cross sections as needed, soil screening readings and soil sample locations, and laboratory analytical data. Tables which summarize laboratory analytical data for all soil samples collected as part of the Site redevelopment, and a summary of the amount of COC impacted soil disposed of off-Site with profiling information included. Appendices which include daily instrument (PIDs, etc) calibration forms, stockpile inspection logs, photographs of work conducted in chronological order, laboratory analytical data sheets and chain of custody forms, weight tickets and soil disposal manifests as applicable. In addition to providing a final summary report, daily field reports documenting observation of soil screening, field instrument readings and analysis of potentially impacted stockpiles will be prepared during the project. The daily field reports will include, as applicable: Soil stockpile records, including Site source of the soil. Location of the stockpile(s). Location of samples within the soil stockpile(s). Laboratory report of soil stockpile sample analyses. Disposition of the stockpile and a statement regarding the stockpile disposal facility. Disposal documentation including copies of manifests and truck trip tickets. Page | 16 10.0 LIMITATIONS The judgments described in this report are professional opinions based solely within the limits of the scope of work authorized and pertain to conditions judged to be present or applicable at the time the work was performed. Future conditions may differ from those described herein, and this report is not intended for future evaluations of this Site unless an update is conducted by a consultant familiar with environmental assessments. This report was compiled from information supplied to FREY Environmental, Inc. from outside sources, and other information that is in the public domain. FREY Environmental, Inc. makes no warranty as to the accuracy of statements made by others, which may be contained in this report, nor are any other warranties or guarantees, expressed or implied, included or intended by the report, except that it has been prepared in accordance with the current accepted practices and standards consistent with the level of care and skill exercised under similar circumstances by other professional consultants or firms performing similar services. Future environmental investigations may reveal site conditions not indicated in the data reviewed by FREY Environmental, Inc. Additionally, changes in standards or regulations applicable to the Site may occur. The findings of this report may be partially or wholly invalidated by changes of which FREY Environmental, Inc. is not aware or has not had the opportunity to evaluate. Environmental assessments provide an additional source on information regarding the environmental conditions of a particular property or facility. The report to the Client is a professional opinion and judgment, dependent upon FREY's knowledge and information obtained during the course of performance of the services. Should you have any questions regarding this SMP, please contact us at (949) 723-1645. Sincerely, FREY Environmental, Inc. Ed Rands Deanna Hoppe Senior Project Engineer Senior Staff Geologist P.E. #58183 Page | 17 REFERENCES FREY (FREY Environmental, Inc.), 2021a; Phase I Environmental Site Assessment, 150 &180 North Santa Anita Avenue, 30 East Santa Clara Street, and 25 & 33 Wheeler Avenue, Arcadia, California, , APNS# 5773-006-004, -005, -010, & -036, FREY Project No. 698-24, dated July 22, 2021. ____, 2021b, Subsurface Soil and Soil Vapor Investigation, Alexan Arcadia, 150 &180 North Santa Anita Avenue, 30 East Santa Clara Street, and 25 & 33 Wheeler Avenue, Arcadia, California, FREY Project No. 698-24, dated July 22, 2021. TABLES TABLE 1 CHEMICAL ANALYSES OF SOIL SAMPLES - TPH & DETECTED VOCs ALEXAN ARCADIA PROJECT 150 & 180 NORTH SANTA ANITA AVENUE, 30 EAST SANTA CLARA STREET, AND 25 & 33 WHEELER AVENUE ARCADIA, CALIFORNIA All concentrations in milligrams per kilogram (mg/kg) unless otherwise indicated Sample Date Sample Depth C6-C8 C9-C16 C17-C32 C33-C44 Total (C6-C44)Acetone Benzene PCE Toluene Designation Sampled (feet bgs)(ug/kg)(ug/kg)(ug/kg)(ug/kg) B1-1 06/01/2021 1 ND<10 ND<10 207 224 430 ND<19 ND<0.96 ND<0.96 ND<0.96 B1-5 06/01/2021 5 ND<4.9 ND<4.9 50 62.3 110 ND<20 ND<1.0 ND<1.0 ND<1.0 B1-10 06/01/2021 10 ND<4.9 ND<4.9 ND<4.9 ND<4.9 ND<4.9 ND<19 ND<0.96 ND<0.96 ND<0.96 B1-15 06/01/2021 15 ND<5.0 ND<5.0 ND<5.0 ND<5.0 ND<5.0 ND<20 ND<1.0 ND<1.0 ND<1.0 B2-1 06/01/2021 1 ND<100 ND<100 1,030 1,270 2,200 ND<20 ND<1.0 ND<1.0 ND<1.0 B2-5 06/01/2021 5 ND<5.0 ND<5.0 ND<5.0 ND<5.0 ND<5.0 ND<20 ND<1.0 ND<1.0 ND<1.0 B2-10 06/01/2021 10 ND<5.1 ND<5.1 ND<5.1 ND<5.1 ND<5.1 ND<20 ND<1.0 ND<1.0 ND<1.0 B2-15 06/01/2021 15 ND<4.8 ND<4.8 ND<4.8 ND<4.8 ND<4.8 ND<20 ND<1.0 ND<1.0 ND<1.0 MP1-5 06/01/2021 5 ----------37 4.2 1.8 1.4 MP1-10 06/01/2021 10 ----------22 ND<1.0 ND<1.0 ND<1.0 MP1-15 06/01/2021 15 ----------31 ND<1.2 ND<1.2 ND<1.2 MP2-5 06/01/2021 5 ----------45 ND<1.6 ND<1.6 ND<1.6 MP2-10 06/01/2021 10 ----------ND<27 ND<1.3 ND<1.3 ND<1.3 MP2-15 06/01/2021 15 ----------ND<16 ND<0.80 ND<0.80 ND<0.80 MP4-1 06/01/2021 1 ND<50 ND<50 430 740 1,300 ND<20 1.1 ND<1.0 1.6 MP4-5 06/01/2021 5 ND<9.8 ND<9.8 122.8 175 290 ND<20 ND<1.0 ND<1.0 ND<1.0 MP4-10 06/01/2021 10 ND<5.0 ND<5.0 ND<5.0 ND<5.0 ND<5.0 ND<20 ND<1.0 ND<1.0 ND<1.0 MP4-15 06/01/2021 15 ND<5.0 ND<5.0 ND<5.0 ND<5.0 ND<5.0 ND<20 ND<0.99 ND<0.99 ND<0.99 MP5-1 06/01/2021 1 ND<100 ND<100 2,190 2,240 4,500 ND<19 ND<0.97 ND<0.97 ND<0.97 MP5-5 06/01/2021 5 ND<5.0 ND<5.0 ND<5.0 ND<5.0 ND<5.0 ND<20 ND<1.0 ND<1.0 ND<1.0 MP5-10 06/01/2021 10 ND<5.0 ND<5.0 ND<5.0 ND<5.0 ND<5.0 ND<20 ND<0.99 ND<0.99 ND<0.99 MP5-15 06/01/2021 15 ND<4.9 ND<4.9 ND<4.9 ND<4.9 ND<4.9 ND<20 ND<0.99 ND<0.99 ND<0.99 Human Health Screening Levels DTSC-Modified Screening Levels (SLs) for Residential Soil [3]--97 2,400 ------330 590 1,100,000 Federal EPA - RSLs for Residential Soil [4]82 97 2,400 ----61,000,000 1,200 2,400 4,900,000 Notes: 1 Soil samples analyzed for total petroleum hydrocarbons (TPH) in accordance with EPA Method No. 8015B 2 Soil samples analyzed for volatile organic compounds (VOCs) in accordance with EPA Method No. 8260B. 3 DTSC values updated June 2020. DTSC SL value shown is the lower of the cancer endpoint or non-cancer endpoint as applicable for aromatic TPH medium (C9-C16) and high (C17-C32). 4 EPA - RSLs updated May 2021. EPA RSL shown is the lower of the cancer endpoint or non-cancer endpoint as applicable for aromatic TPH low (C6-C8), medium (C9-C16) and high (C17-C32). mg/kg milligrams per kilogram ug/kg micrograms per kilogram --Not sampled, not listed, or not applicable TPH Carbon Chain [1]Detected VOCs [2] FREY Environmental, Inc.Table 1 698-24 TABLE 2SUMMARY OF SOIL SAMPLE LABORATORY ANALYTICAL RESULTS - METALS ALEXAN ARCADIA PROJECT150 & 180 NORTH SANTA ANITA AVENUE, 30 EAST SANTA CLARA STREET, AND 25 & 33 WHEELER AVENUE ARCADIA, CALIFORNIA All concentrations in milligrams per kilogram (mg/kg) unless otherwise indicated Sample Date Sample Depth Designation Sampled (feet bgs)Antimony Arsenic Barium Beryllium Cadmium Chromium Cobalt Copper Lead Mercury Molybdenum Nickel Selenium Silver Thallium Vanadium Zinc B1-1 06/01/2021 1 ND<3.08 ND<2.56 31.1 0.659 ND<0.513 15.1 8.99 19.4 ND<5.13 ND<0.0.0847 ND<0.513 11.1 ND<0.513 ND<1.03 ND<5.13 32.4 44.2 B1-5 06/01/2021 5 ND<3.09 ND<2.58 40.5 0.431 ND<0.515 9.54 7.34 18.4 ND<5.15 ND<0.0.0847 ND<0.515 9.31 ND<0.515 ND<1.03 ND<5.15 23.8 37.5 B1-10 06/01/2021 10 ND<3.11 ND<2.59 27.0 0.271 ND<0.518 5.6 4.61 11.8 ND<5.18 ND<0.0.0833 ND<0.518 5.58 ND<0.518 ND<1.01 ND<5.18 15.2 19.2 B1-15 06/01/2021 15 ND<3.03 ND<2.53 18.1 ND<0.253 ND<0.505 4.54 3.50 7.71 ND<5.05 ND<0.0.0820 ND<0.505 4.38 ND<0.505 ND<1.01 ND<5.05 12.1 13.8 B2-1 06/01/2021 1 ND<3.02 ND<2.51 46.4 0.449 ND<0.503 10.9 7.41 14.6 9.72 ND<0.0.0820 ND<0.503 11.0 ND<0.503 ND<1.01 ND<5.05 24.6 39.9 B2-5 06/01/2021 5 ND<3.05 ND<2.54 26.2 ND<0.254 ND<0.508 5.19 3.84 11.1 ND<5.08 ND<0.0.0877 ND<0.508 4.77 ND<0.508 ND<1.02 ND<5.08 12.4 17.4 B2-10 06/01/2021 10 ND<3.00 ND<2.50 20.5 ND<0.250 ND<0.500 5.58 3.50 8.78 ND<5.00 ND<0.0.0862 ND<0.500 4.59 ND<0.500 ND<1.00 ND<5.00 11.0 16.2 B2-15 06/01/2021 15 ND<2.94 ND<2.45 24.1 ND<0.245 ND<0.490 4.71 3.65 9.25 ND<4.90 ND<0.0.0806 ND<0.490 4.08 ND<0.490 ND<0.980 ND<4.90 13.2 15.8 MP4-1 06/01/2021 1 ND<3.08 ND<2.56 54.3 0.627 ND<0.513 23.0 9.17 19.1 11.8 ND<0.0.0877 0.797 12.4 ND<0.513 ND<1.03 ND<5.13 33.4 45.4 MP4-5 06/01/2021 5 ND<3.05 ND<2.54 62.0 0.560 ND<0.508 12.9 9.62 23.5 ND<5.08 ND<0.0794 ND<0.508 11.9 ND<0.508 ND<1.02 ND<5.08 32.8 43.8 MP4-10 06/01/2021 10 ND<2.95 ND<2.46 41.1 0.350 ND<0.493 15.0 6.64 16.6 ND<4.93 ND<0.0794 0.501 9.65 ND<0.493 ND<0.985 ND<4.93 23.1 28.8 MP4-15 06/01/2021 15 ND<2.99 ND<2.49 23.9 0.265 ND<0.498 6.11 4.20 9.90 ND<4.98 ND<0.0.0877 ND<0.498 4.86 ND<0.498 ND<0.995 ND<4.98 14.8 18.1 MP5-1 06/01/2021 1 ND<3.03 ND<2.53 80.2 0.307 ND<0.505 10.5 6.35 15.3 31.9 ND<0.0.0820 ND<0.505 11.7 ND<0.505 ND<1.01 ND<5.05 21.9 40.7 MP5-5 06/01/2021 5 ND<3.03 ND<2.53 31.9 0.261 ND<0.505 6.62 4.68 11.7 ND<5.05 ND<0.0.0877 ND<0.505 5.55 ND<0.505 ND<1.01 ND<5.05 15.7 19.4 MP5-10 06/01/2021 10 ND<2.91 ND<2.43 30.0 0.258 ND<0.485 6.90 4.06 9.98 ND<4.85 ND<0.0.0806 ND<0.485 4.54 ND<0.485 ND<0.971 ND<4.85 14.3 18.6 MP5-15 06/01/2021 15 ND<3.00 ND<2.50 26.6 ND<0.250 ND<0.500 4.95 3.95 9.82 ND<5.00 ND<0.0.0820 ND<0.500 4.85 ND<0.500 ND<1.00 ND<5.00 13.7 16.9 Human Health Screening Levels DTSC-Modified Screening Levels (SLs) for Residential Soil - mg/kg *0.11 15 5.2 36,000 80 1.0 490 390 390 Federal EPA Region 9 - RSLs for Residential Soil - mg/kg*31 0.68 15,000 160 71 23 3,100 400 11 390 390 390 390 23,000 Soil Disposal CriteriaCalifornia - TTLC Regulatory Limit - mg/kg 500 500 10,000 75 100 2,500 8,000 2,500 1,000 20 3,500 2,000 100 500 700 2,400 5,000 California - STLC Regulatory Limit - mg/l 15 5 100 0.75 1 5 80 25 5 0.2 350 20 1 5 7 24 250 Federal - TCLP) Regulatory Limit - mg/l 5 100 1 5 5 0.2 1 5 Notes: 1) ND = not detected above laboratory detection limit. 2) CCR - Title 22 Metals analyzed in accordance with EPA Method No. 6010B/7471A. 3) Total Threshold Limit Concentration (TTLC) California Code of Regulations Title 22. 4) Soluble Threshold Limit Concentration (STLC) California Code of Regulations Title 22. 5) Toxic Characteristic Leaching Procedure (TCLP) 40 Code of Federal Regulations. 6) DTSC SL values updated June 2020. DTSC SL value shown is the lower of the cancer endpoint or non-cancer endpoint as applicable. 7) EPA RSLs updated May 2021. EPA RSL shown is the lower of the cancer endpoint or non-cancer endpoint as applicable. "--" = Not Analyzed * = In Southern California, an arsenic concentration of 12 mg/kg is an allowable level to assess whether arsenic is a constituent of potential concern (DTSC, 2008). FREY Environmental, Inc.Table 2 Project No. 698-24 TABLE 3 SUMMARY OF SOIL VAPOR SAMPLE LABORATORY RESULTS - DETECTED VOCs ALEXAN ARCADIA PROJECT 150 & 180 NORTH SANTA ANITA AVENUE, 30 EAST SANTA CLARA STREET, AND 25 & 33 WHEELER AVENUE ARCADIA, CALIFORNIA (measurements in micrograms per cubic meter μg/m3) SAMPLE DATE Chloro-Dichlorodifluoro-Ethyl-Trichlorofluoro-Total DESIGNATION SAMPLED 2-Butanone [4]Acetone [4]Benzene [4]methane [4]methane [4]DIPE [4]benzene [4]PCE [4]Toluene [4]methane [4]Xylenes [4] MP1-5'06/09/2021 9.2 19 ND<2.2 ND<1.5 110 ND<12 ND<3.1 480 ND<2.7 120 ND<3.1 MP1-15'06/09/2021 10 25 ND<2.2 ND<1.4 6.7 ND<12 ND<3.0 410 ND<2.6 57 ND<3.0 MP2-5'06/09/2021 11 ND<2.2 ND<1.4 3.5 ND<11 ND<3.0 260 ND<2.6 27 ND<3.0 MP2-15'06/09/2021 16 36 ND<2.2 ND<1.5 4.3 14 ND<3.1 240 6.2 38 ND<3.1 MP3-5'06/09/2021 7.7 21 ND<2.2 ND<1.4 ND<3.4 ND<11 ND<3.0 62 ND<2.6 ND<7.7 ND<3.0 MP4-5'06/09/2021 17 ND<2.7 ND<1.7 ND<4.2 ND<14 ND<3.7 410 ND<3.2 93 ND<3.7 MP4-15'06/09/2021 16 36 ND<2.7 ND<1.7 ND<4.1 ND<14 ND<3.6 330 ND<3.2 96 ND<3.6 MP5-5'06/09/2021 10 21 ND<2.5 ND<1.6 ND<3.8 ND<13 ND<3.3 47 4.8 32 ND<3.3 MP5-15'06/09/2021 27 54 5.9 1.6 ND<3.7 ND<13 3.4 50 10 63 3.6 DTSC HHRA Note 3 [1]NL NL 3.2 NL NL NL NL 15 10,333 NL NL NL 1,066,667 12 3,133 3,333 24,333 37 367 173,333 NL 3,333 NL 1,100,000 3.2 3,100 NL NL 37 15 10,000 NL 3,500 NOTES: [1]DTSC Human Health Risk Assessment Note 3. Updated June 2020 The screening level was calculated by dividing the ambient residential air concentration presented in Table 3 of Note 3 by an attenuation factor of 0.03. [2]USEPA Regional Screening Level (RSL) residential air table, updated May 2021. The screening level was calculated by dividing the residential air concentration by an attenuation factor of 0.03. [3] [4]Volatile organic compounds (VOCs) were analyzed in accordance with EPA Method No. TO-15. DIPE = Di-isopropyl ether PCE = Tetrachloroethene ND = Not detected at or above the given detection limit. NL = Not Listed NS = Not sampled San Francisco ESLs [3] EPA RSL [2] San Francisco Vapor Environmental Screening Levels (ESLs) for Subslab/Soil Gas with Cancer Risk for Residential Vapor Intrusion Human Health Screening Risk Levels (HHRLs), January 2019. FREY Environmental, Inc.Table 3 Project No. 698-24 FIGURES SITE LOCATION MAP DATE:PROJECT No.:CLIENT: FILE NAME:FIGURE 1 NOTE: APPROXIMATE SCALE IN MILES NO R T H Base map includes information from (N) Mount Wilson and (S) El Monte, 2012,USGS 7.5 minute, California topographic quadrangles. 1. N S 698-24-SL.AI 04/2023698-24 150 & 180 NORTH SANTA ANITA AVENUE,34 EAST SANTA CLARA STREETARCADIA, CALIFORNIA ALEXAN ARCADIA PROJECT 34 EAST SANTA CLARA STREET ARCADIA, CALIFORNIA 04/2023 MODIFIED BY DH 180 N SANTA ANITA AVE 150 N SANTA ANITA AVE 100 N SANTA ANITA AVE APPENDIX A ROUGH GRADING PLAN N. S A N T A A N I T A A V E WHEELER AVE E SANTA CLARA ST MBA1 LCP PANEL EV3 LINE OF SHORING REFER TO SHORING PLANS FOR DETAILS LINE OF SHORING REFER TO SHORING PLANS FOR DETAILS 5. 1 % 470.42 FG 466.75 FG PAD FG 470.42 PAD FG 476.92 PL R/W 5. 0 0 ' PROPOSED 5' SIDEWALK EASEMENT TO THE CITY PROPOSED 5' SIDEWALK EASEMENT TO THE CITY R/W R/W PL PL R/W 2' SIDEWALK EASEMENT TO THE CITY PL R/W R/W PROPOSED ALLEY IMPROVEMENTS PER SEPARATE PLAN & PERMIT PROPOSED DRIVEWAY & SIDEWALK IMPROVEMENTS PER SEPARATE PLAN & PERMIT PROPOSED DRIVEWAY & SIDEWALK IMPROVEMENTS PER SEPARATE PLAN & PERMIT PROPOSED DRIVEWAY & SIDEWALK IMPROVEMENTS PER SEPARATE PLAN & PERMIT 1. 0 : 1 LINE OF SHORING REFER TO SHORING PLANS FOR DETAILS 4. 1 % 2. 0 % 470.42 FG 469.84 FG 466.75 FG 476.92 FG 465.75 FG 1. 0 : 1 476.92 FG 464.70 FG 464.70 FG 465.75 FG 2. 0 % 2. 0 % LINE OF SHORING REFER TO SHORING PLANS FOR DETAILS 1' WIDE STREET DEDICATION TO THE CITY4' STREET DEDICATION TO THE CITY 3' WIDE STREET DEDICATION TO THE CITY V: \ 1 A R C 0 4 0 1 0 0 \ E N G R \ S H E E T S \ C 2 . 0 0 R o u g h G r a d i n g P l a n . d w g 7/ 2 5 / 2 0 2 3 4 : 2 6 P M 57 9 0 F L E E T S T R E E T , S U I T E 1 4 0 CA R L S B A D , C A 9 2 0 0 8 REVISIONS ISSUE DATE PROJECT NUMBER: 20-301 AL E X A N A R C A D I A MI X E D - U S E / M U L T I - F A M I L Y H O U S I N G PR O J E C T 27 2 2 0 T U R N B E R R Y L A N E , SU I T E 1 9 0 VA L E N C I A , C A 9 1 3 5 5 66 1 . 2 1 9 . 6 0 0 0 50% DD 11/07/2022 34 E . S A N T A C L A R A S T . AR C A D I A , C A 9 1 0 0 6 100% DD 12/19/2022 50% CD 02/13/2023 PC SUBMITTAL 04/24/20236 5 PC SUBMITTAL 07/31/20237 C2.00 ROUGH GRADING PLAN APPENDIX B SCAQMD VARIOUS LOCATIONS RULE 1166 PERMIT APPENDIX C SITE-SPECIFIC HEALTH AND SAFETY PLAN HEALTH AND SAFETY PLAN ALEXAN ARCADIA PROJECT 34 EAST SANTA CLARA STREET ARCADIA, CALIFORNIA APNS# 5773-006-004, -005, -010, & -036 Prepared by: FREY Environmental, Inc. 2817A Lafayette Avenue Newport Beach, California 92663-3715 (949) 723-1645 freyinc@freyinc.com Project No.: 698-24 April 5, 2023 FREY Environmental, Inc. i TABLE OF CONTENTS SECTION TITLE PAGE 1.0 INTRODUCTION 1 2.0 SITE DESCRIPTION 1 3.0 PROPOSED DEVELOPMENT DESCRIPTION 1 4.0 WORK DESCRIPTION 1 5.0 EVALUATION OF POTENTIAL PUBLIC EXPOSURE TO HAZARDS 2 5.1 INHALATION HAZARDS 2 5.2 DERMAL EXPOSURE HAZARDS 2 5.3 EXPLOSION HAZARDS 2 5.4 PHYSICAL HAZARDS 3 6.0 MONITORING EQUIPMENT 3 7.0 CONTROL METHODS 3 7.1 SITE SECURITY 3 7.2 DUST 3 7.3 NOISE 3 7.4 OPEN EXCAVATIONS 3 7.5 STOCKPILED SOILS 5 7.6 BMPs 4 8.0 SITE SAFETY PERSONNEL 4 8.1 STAFF ORGANIZATION AND RESPONSIBILITIES 4 8.2 HEALTH AND SAFETY MANAGER 5 8.3 PROJECT MANAGER 5 8.4 SITE SUPERVISOR 5 8.5 WORK FORCE 6 9.0 EMERGENCY PLANNING 6 10.0 SIGN-IN SHEET 7 FREY Environmental, Inc. ii TABLE OF CONTENTS (Continued) LIST OF FIGURES 1 SITE LOCATION MAP 2 SITE VICINITY SKETCH LIST OF APPENDICES A MAP TO HOSPITAL FREY Environmental, Inc. 1 1.0 INTRODUCTION FREY Environmental, Inc. (FREY) has been retained by Maple Multi-Family Land CA, L.P. to oversee excavation and removal of soils at the subject location (Site, Figure 1) that may contain the following constituents of concern (COCs): total petroleum hydrocarbons (TPH) and chlorinated volatile organic compounds (VOCs). The proposed development consists of the construction of mixed-use commercial/residential buildings with subterranean parking garage. This Health and Safety Plan (HASP) presents the health and safety procedures that are intended to reduce the possibility of physical or chemical incidents from occurring at the Site. The provisions of this plan apply to employees of FREY and its subcontractors. Regulatory agencies and Site personnel are expected to observe the safety guidelines established by their respective organizations in addition to the requirements of this document. The overall hazard assessment on the project is estimated to be low with proper adherence to the Soil Management Plan (SMP) for the project and this HASP. Best engineering practices and controls will be in effect at the Site at all times during excavation activities. 2.0 SITE DESCRIPTION The Site consists three parcels and a portion of a fourth parcel comprising approximately 2.5 acres. The Site is currently the location of several commercial/office buildings with associated parking lots. The prevailing wind direction for the Site vicinity is influenced by the Pacific Ocean and typically comes from the west. The surrounding community and land use are primarily commercial. 3.0 PROPOSED DEVELOPMENT DESCRIPTION A mixed-use development is to be built at the Site with two levels of 5subterranean parking. The proposed grading plan is to excavate the Site to depths of up to 20 feet below ground surface (bgs) in areas. 4.0 WORK DESCRIPTION Based on a previous subsurface environmental assessment conducted at the Site, VOCs and petroleum hydrocarbons will be encountered during grading activities during the subject project. As such, this HASP incorporates information regarding the management and handling of soils suspected of containing VOCs and petroleum hydrocarbons. Background information regarding the subsurface investigation conducted at the Site that assessed for the presence of COCs are discussed in the Soil Management Plan for the proposed Site re-development, prepared by FREY. FREY Environmental, Inc. 2 5.0 EVALUATION OF POTENTIAL EXPOSURE TO HAZARDS 5.1 CHEMICAL HAZARD PCE and benzene have been classified as known or suspected human or mammalian carcinogens. Direct skin or eye contact or exposure to high vapor concentrations may result in dermatitis, eye and/or lung irritation; acute overexposure may cause central nervous system depression, liver and or kidney damage, convulsion ns, coma, and even death. Symptoms can include headache, nausea, dizziness, increased perspiration, staggering gait, and slowing of mental ability. 5.2 INHALATION HAZARDS The major toxicity concerns is PCE. PCE has a Threshold Limit Value (TLV) of 25 ppm, which is defined as the average exposure for a period of 8 hours per day, 5 days per week that is believed will not cause harm to worker health. Vapor concentrations expected to encountered during soil excavation and sampling are not expected to exceed recommended exposure limits, based on soil vapor data collected from the Site. However, respiratory protection (level C) must be used if VOCs concentrations reach 25 ppm. The community at large will not be allowed within the project fence. 5.2 DERMAL EXPOSURE HAZARDS Contact of sufficient duration to cause significant absorption of toxic components is highly unlikely. Repeated daily or prolonged contact with excavated soils may be expected to defat the skin and perhaps, over a long period of time, lead to irritation and dermatitis. For this reason, direct contact with highly contaminated soils should be avoided when possible. However, if prolonged skin contact does occur, the exposed areas shall be washed with soap and water and rinsed thoroughly. The community at large will not be allowed within the 25-foot work zone minimizing any chance of dermal contact. 5.3 EXPLOSION HAZARDS Based on Site assessment subsurface investigations conducted to date, the explosion risk to on-Site personnel and the community at large associated with VOC and/or petroleum hydrocarbons in subsurface soils is estimated to be minimal. FREY Environmental, Inc. 3 5.4 PHYSICAL HAZARDS Sufficient attention must be paid to other possible hazards at the site including but not limited to the improper use of heavy equipment, hand tools, tripping on tools or other objects, dehydration or sun stroke or lack of oxygen through the blockage of face masks. Access and egress hazards have the potential to exist when large vehicles including excavating equipment, soil transport trucks, and shoring equipment are approaching, maneuvering and leaving the Site. Drivers will be instructed on proper access and egress points to minimize the disturbance to adjacent street traffic. If required, a traffic control plan and trucking route plan will be utilized. 6.0 AIR MONITORING Visual air monitoring is to be conducted during excavation and loading of COC impacted soils. Dust suppression will be conducted via wetting soils during excavation and loading as warranted. Under no circumstance will dust be allowed to leave the property boundaries. 7.0 CONTROL METHODS 7.1 SITE SECURITY The entire Site will be fenced with six-foot-high chain-link fence. A 25-foot work zone around areas where impacted soils will be excavated will be delineated using consisting of cones, barricades and caution tape. 7.2 DUST To avoid dust generation, excavation areas will be controlled with soil wetting and physical barriers (plastic sheeting), as needed. Wetted surfaces will be visually wet, and care shall be taken during wetting procedures to avoid generation of runoff. 7.3 NOISE Excavation activities will be conducted between the hours of 7 a.m. and 7 p.m., Monday through Saturday, and no work will be conducted on Sunday. 7.4 OPEN EXCAVATIONS Open excavations are to be barricaded from access by the general public at all times. FREY Environmental, Inc. 4 7.5 STOCKPILED SOILS Impacted soil pile size must not exceed 400 cubic yards. Impacted soil piles must either be placed on an asphalt or concrete surface or on 4-millimeter plastic sheeting placed upon an unpaved surface. The impacted soil piles must be covered with a minimum 2-millimeter plastic sheeting. Seams in the plastic sheeting must overlap a minimum of 24 inches. Sandbags or other appropriate weighting objects must be placed on the overlapping seams to secure the sheeting in place. The working face of the potentially impacted soil pile will be moistened with water to prevent petroleum hydrocarbon emissions during work and will be recovered during periods of inactivity which exceed one hour. At the end of each workday, all soil piles shall be completely covered and securely anchored to prevent any exposure of soil to wind or rain. 7.6 BMPs Necessary erosion control materials will be provided on-Site to facilitate rapid installation of erosion control facilities. In the event of a rainstorm, de-silting facilities will be constructed and implemented as necessary. 8.0 SITE SAFETY PERSONNEL 8.1 STAFF ORGANIZATION AND RESPONSIBILITIES While the Health and Safety manager supervises the overall Health and Safety Program, the responsibility for health and safety extends throughout the organization from top management to every employee. FREY shall have on-Site at all times responsible personnel with the knowledge, experience and authority to oversee the work in progress in a responsible and appropriate manner for the work. The personnel shall have adequate training and experience with TPH/VOCs containing soil. Furthermore, there shall be on-site at all times at least one person capable of administering first aid in the case of injury. Responsibility Contact Person Emergency Phone Number Fire/Ambulance --- 911 Designated Emergency Medical Clinic: Methodist Hospital 300 Huntington Drive Arcadia, CA 91007 Emergency Room (626) 898-8000 FREY Project Engineer Ed Rands (949) 723-1645 x122 FREY Health and Safety Manager Ed Rands (949) 723-1645 x122 FREY Project Manager Ed Rands (949) 723-1645 x122 FREY Environmental, Inc. 5 Responsibility Contact Person Emergency Phone Number FREY Site Supervisor Chris Melendez (949) 887-5311 Poison Control --- (800) 222-1222 National Response Center --- (800) 424-8802 Center for Disease Control --- (800) 232-4636 A map and directions from the work site to Methodist Hospital - Arcadia is included with this HASP in Appendix A. 8.2 HEALTH AND SAFETY MANAGER The Health and Safety Manager formulates, administers, and coordinates programs for each company to reduce the risk of loss due to employee injury, regulatory non-compliance, general liability, fire, theft, or damage. The Health and Safety manager will develop written, detailed policies and procedures covering elements in the corporate Health and Safety program. The Health and Safety Manager is responsible for the implementation and enforcement of this HASP and the corporate Health and Safety Program, along with the Project Manager. The Health and Safety Manager ensures that the proper personal protective equipment is available and utilized by all workers, as required. The Health and Safety manager is responsible for periodically reviewing the job site to ensure that no unsafe acts or conditions exist and to keep records of findings and any corrective actions taken. The Health and Safety Manager oversees initial site- specific training of on-site personnel, provided on-site consultation, supervises the air monitoring plan, performs safety audits, and documents, reviews, and amends the HASP as site conditions change. 8.3 PROJECT MANAGER The Project Manager has full responsibility for ensuring that the policies and procedures outlined in the HASP are implemented on his/her respective projects. The Project Manager, by example, establishes an attitude of concern for safety matters and works to recognize and resolve safety violations and items of non-compliance. 8.4 SITE SUPERVISOR The Site Supervisor, capable by way of knowledge, experience, and training, is to oversee all aspects of this project wherein lead exposure may be an issue and to direct the on-Site activities so as to minimize such exposures. The Site Supervisor will see that effective air monitoring is performed for the possible presence of lead containing dust and assist in formulating modifications of ongoing activities. FREY Environmental, Inc. 6 8.5 WORK FORCE It is the responsibility of all employees to work in a manner that will prevent injury and exposure to them and to other employees. All employees are responsible for obeying safety rules and regulations as provided to them by their job training, and reporting unsafe acts or conditions to their supervisors. 9.0 EMERGENCY PLANNING The Site Supervisor will plan emergency egress routes and discuss them with Site personnel during tail gate meetings prior to start of filed activities. Emergency planning will include establishing and posting emergency warning signals and evacuation routes in case of an emergency. FREY Environmental, Inc. 7 10.0 SIGN-IN-SHEET By signing this table, personnel acknowledge that they have read the above HASP and are familiar with its provisions. Name (print) Signature Date Company FREY Environmental, Inc. 8 Name (print) Signature Date Company FREY Environmental, Inc. FIGURES SITE LOCATION MAP DATE:PROJECT No.:CLIENT: FILE NAME:FIGURE 1 NOTE: APPROXIMATE SCALE IN MILES NO R T H Base map includes information from (N) Mount Wilson and (S) El Monte, 2012,USGS 7.5 minute, California topographic quadrangles. 1. N S 698-24-SL.AI 04/2023698-24 150 & 180 NORTH SANTA ANITA AVENUE,34 EAST SANTA CLARA STREETARCADIA, CALIFORNIA PARKING LOT SITE AND IMMEDIATE SITE VICINITY FIGURE 2 DATE:PROJECT No.:CLIENT: FILE NAME: APPROXIMATE SCALE IN FEET NOTES: NO R T H LEGEND 0 15075 1. 2. All locations and dimensions are approximate. Base photo from Google Earth, accessedon April 20, 2021.N S A N T A A N I T A A V E N U E WHEELER AVENUE E SANTA CLARA ST REI STORE VACANT PARKING GARAGE GENERATORS AUTO DEALERSHIP MEDICAL & SERVICES OFFICES PARKING LOT POST OFFICE 698-24-ISV.AI 04/2023698-24 SITE 5773-006-036 5773-006-010 5773-006-0055773-006-004 34 EAST SANTA CLARA STREETARCADIA, CALIFORNIA 18 0 15 0 25 33 30 FOOTPRINT FORMER LAUNDRY 122 N SANTA ANITA AVE (LOCATION APPRX) FREY Environmental, Inc. APPENDIX A MAP TO HOSPITAL Map data ©2021 500 ft These directions are for planning purposes only. You may nd that construction projects, tra c, weather, or other events may cause conditions to differ from the map results, and you should planyour route accordingly. You must obey all signs or notices regarding your route. Arcadia, CA 91006 300 Huntington Dr, Arcadia, CA 91007 150 N Santa Anita Ave 1. Head north on N Santa Anita Ave toward E Santa Clara St 2. Turn left at the 1st cross street onto Santa Clara St 3. Use any lane to turn right onto Huntington Dr Methodist Hospital 177 ft 0.3 mi 0.5 mi Drive 0.8 mile, 2 min150 North Santa Anita Avenue, Arcadia, CA to Methodist Hospital