Santa Ana Unified School District, Removal Action Work Plan for the Proposed Heroes Elementary School Site

Santa Ana Unified School District, Removal Action Work Plan for the Proposed Heroes Elementary School Site

The Removal Action Work Plan (RAW) proposes to excavate contaminated soil from 19 areas on-site. Some of the chemicals in the soil include arsenic, dieldrin, DDE, DDT, lead, PCBs and chlordane. PCBs are most likely a result of the historical use of insulating oil in the pole-mounted transformer on-site. The remaining chemicals most likely resulted from the site's historical agricultural use. Arsenic concentrations range from 1.4 mg/kg to 310 mg/kg; dieldrin concentrations range from non-detect to 1500 ug/kg; DDE concentrations range from non-detect to 7400 ug/kg; DDT concentrations range from non-detect to 10,000 ug/kg; lead concentrations range from 1.0 mg/kg to 1300 mg/kg; PCB concentrations range from non-detect to 770 ug/kg; and chlordane concentrations range from non-detect to 1900 ug/kg. Approximately 2,800 total cubic yards of impacted soil will be disposed of off-site. Confirmation samples will verify the site-specific cleanup goals for arsenic (11 mg/kg), dieldrin (0.0358 mg/kg), DDE (1.68 mg/kg), DDT (1.68 mg/kg), lead (255 mg/kg), PCBs (0.236 mg/kg) and chlordane (0.44 mg/kg) have been achieved. The site-specific cleanup goals have been derived from a risk-based soil-screening assessment that is health protective and approved by DTSC's Human and Ecological Risk Division, for unrestricted land use. Prominent adjoining land uses include residential properties (north, south, east and west), and a police department administration building (south). The nearest sensitive receptors are the residences approximately 15 feet from the nearest excavation area on-site. In order to prevent any potential exposure to the chemicals of concern by adjacent residents and site personnel, all doors, windows, air conditioning units, and heating systems, adjacent to the excavation zone, will be taped and covered. Excavation areas will be controlled to avoid dust generation with physical barriers (such as perimeter fencing with tarps) and soil wetting. Additionally, airborne dust monitoring will be conducted using real-time, data-logging aerosol monitors, to verify and document the effectiveness of dust suppression in the work zone and the immediate perimeter, including the fence-line of the nearest receptor, during the field activities. No excavation will be conducted in times of high wind conditions. The site will be secured using temporary chain-link fencing with locked gates to restrict unauthorized access to the stockpiles and work area. The RAW provides additional field provisions to be put in place, in the event of adverse weather, to control run-off, ponding or erosion. Excavation, characterization sampling and off-site disposal activities for the impacted soil are expected to take approximately 60 calendar days to complete. Excavated soil will be segregated into stockpiles of potentially hazardous wastes; potentially California regulated hazardous wastes, and potentially non-hazardous wastes. Excavated soil will be placed in a temporary staging area until transported off-site for disposal. The soil will be stockpiled on impermeable material and covered with tarps to prevent run-on and/or dust generation and bermed to contain any run-off, or placed in covered roll-off bins. Soil will be sampled for profiling purposes to ensure acceptance by the appropriate licensed, off-site disposal. Lead concentrations greater than 1,000 mg/kg, the non-RCRA hazardous waste concentration, may be classified as a non-RCRA hazardous waste. Total lead concentrations greater than 350 mg/kg but less than the non-RCRA hazardous waste concentration of 1,000 mg/kg may not be disposed of at any landfill other than a Class 1 disposal facility, in California, pursuant to Health and Safety Code, Section 25157.8. As such, the excavated soil will be handled and managed as if it is a hazardous waste, until stockpile profiling is completed and the waste characteristics are known. Soil designated as non-hazardous waste will be transported off-site to the Bradley Landfill and Recycling Center in Sun Valley, California. Waste that is characterized as not-RCRA California-designated hazardous waste, RCRA hazardous waste, or TSCA waste for landfill (i.e., PCBs in soil) will be transported to the Waste Management, Incorporated, Kettleman Hills Facility in California. Any hazardous wastes shipped off-site will be transported by a registered hazardous waste hauler under a uniform hazardous waste manifest. Land ban treatment and disposal requirements will be followed as necessary. The excavated soil is estimate to require removal by approximately 280 trucks, covered, and transported under proper manifest to the pre-approved facilities for disposal. All vehicles will be decontaminated prior to exiting the loading area. Transportation of contaminated soils will be on arterial streets and/or freeways, minimizing any potential impact on the local neighborhood. Trucks will be staged to avoid impacts on the local streets. Transportation will be timed to avoid rush traffic hours. Transport of the material will be conducted in accordance with the transportation plan included in the RAW, prepared under the Cal-EPA DTSC Transportation Plan Preparation Guidance for Site Remediation, 1994. The will minimize potential health, safety, and environmental risks resulting from the movement of material and/or equipment during site cleanup. The transport trucks will exit the site on Civic Center Drive and travel west, for approximately 800 feet, to Bristol Street and travel north, for approximately two miles on Bristol Street, to the 22 Freeway. Multiple travel routes to the approved, off-site disposal facility are available on the freeway system. The total travel distance from the site to the Bradley Landfill and Recycling Center is approximately 50 miles, and to Kettleman Hills Facility is approximately 210 miles.

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