Clover Elementary School Soil Cleanup
Summary
SCH Number
2025040664
Public Agency
Los Angeles Unified School District
Document Title
Clover Elementary School Soil Cleanup
Document Type
NOE - Notice of Exemption
Received
Posted
4/14/2025
Document Description
The Project entails the implementation of a cleanup plan for arsenic impacted soil, which includes excavation and disposal of impacted soil located in a portion of the construction area of the Clover ES Classroom Replacement Project (Figure 1). The Los Angeles Unified School District Board of Education approved the Clover ES Classroom Replacement Project’s budget of $105,819,442 on March 12, 2024. The Soil Cleanup portion of the Classroom Replacement Project is estimated to cost approximately $910,640.
Soil sampling was performed as part of the Preliminary Environmental Assessment Equivalent (PEA-E) and to address compliance with South Coast Air Quality Management District (SCAQMD) during the Clover ES Classroom Replacement Project. Arsenic was reported in soil samples above the Department of Toxic Substance Control (DTSC) upper bound estimate (95th percentile) for background concentration for southern California of 12 milligrams per kilograms (mg/kg). The elevated arsenic concentrations (exceeding 12 mg/kg) were present in most of the shallow soil samples collected within the construction zone, including the unpaved areas (recess yards, landscape areas, tree wells, etc.). The locations of the impacted soils could not be linked to current activities or structures at the school and are regarded as non-point source contaminants. A complete copy of the report for this investigation is included in the Soil Removal Plan (SRP) . This SRP was prepared to describe the procedure for removing the soil with elevated arsenic concentrations to below the DTSC background concentration in the unpaved area of the school.
Based on the site characterization data, the SRP includes the following elements:
• Excavation and off-site disposal of soils with arsenic concentrations =12 milligrams per kilogram from eleven Areas of Concern (AOCs).
• Excavation of soil to a minimum depth of 2 feet below ground surface, except in one area where excavation will extend to 3 feet below ground surface.
• Additional excavation of impacted soil from 36 tree wells to a depth of approximately one foot or a feasible depth that does not compromise the health of the trees. A geotextile barrier will be placed at the base of each tree well excavation prior to backfilling.
• Verification sampling of the excavation to confirm arsenic impacted soil has been removed.
• After confirmation sample results confirm the remedial goals, excavation areas will be graded or backfilled with clean fill material.
The SRP identifies best management practices designed to limit potential short-term risks (e.g., the exposure of students, staff, and onsite workers to chemical of concerns during soil excavation activities) through the proper use of institutional controls, such as engineering controls, security measures, personal protective equipment (PPE), and adherence to established health and safety procedures, including the application of water spray to suppress fugitive dust emissions during the excavation, the proper handling, transportation and disposal of impacted soil, and enforcing speed limits at the Project site. All soil removal activities will follow generally acceptable practices, institutional controls, and State, federal, and local agency guidelines, including, but not limited to, those of the: Environmental Protection Agency (EPA), South Coast Air Quality Management District (SCAQMD), Occupational Safety and Health Administration (OSHA)/National Institute of Occupational Safety and Health (NIOSH), and Regional Water Quality Control Board. Soil removal will occur in the summer when students and staff are off campus.
The Project will be implemented pursuant to all applicable State, federal, and local regulations, and all applicable LAUSD specifications, standards, and/or guidelines, including those in compliance with the California Environmental Quality Act (CEQA) and the updated Standard Conditions of Approval for District Construction, Upgrade, and Improvements Projects (SCs) as adopted by the Board of Education in December 2023. LAUSD’s SCs, design guidelines, and best management practices are designed to be incorporated into the Project design in order to avoid or limit potential adverse impacts associated with the District’s projects.
The beneficiaries of this Project are the Clover ES students, faculty, staff, families, school supporters, and the community at large who may request access to the facilities and grounds of the Campus pursuant to the Civic Center Act (CA Ed. Code Sections 38130 - 38139).
Contact Information
Name
Christy Wong
Agency Name
Los Angeles Unified School District
Job Title
CEQA Project Manager
Contact Types
Lead/Public Agency
Phone
Location
Cities
Los Angeles
Counties
Los Angeles
Regions
Southern California
Other Location Info
The Clover Elementary School Soil Cleanup Project (Project) will be located on the 15.35-acre Clover Elementary School (Clover ES) campus. The Clover ES campus (Campus) is located at 11020 Clover Avenue in the Palms neighborhood of the City of Los Angeles. It is bound by Clover Avenue to the north, Military Avenue to the east, Queensland to the south, and South Bentley Avenue to the west. The Campus is located in an urbanized community primarily consisting of commercial uses, multi-family, and single-family residences.
Notice of Exemption
Exempt Status
Categorical Exemption
Type, Section or Code
CEQA Guidelines Section 15330
Reasons for Exemption
Section 15330 - Minor Actions to Prevent, Minimize, Stabilize, Mitigate or Eliminate the Release or Threat of Release of Hazardous Waste or Hazardous Substances.
Class 30 consists of any minor cleanup actions taken to prevent, minimize, stabilize, mitigate, or eliminate the release or threat of release of a hazardous waste or substance which are small or medium removal actions costing $1 million or less.
The Project entails the implementation of a SRP for arsenic impacted soil; excavation of impacted soil; and disposal of impacted soil. Based on the site characterization data, a cleanup plan has been developed for the Site. The cleanup plan includes the following elements:
• Excavation and off-site disposal of soils with arsenic concentrations =12 milligrams per kilogram from eleven Areas of Concern (AOCs).
• Excavation of soil to a minimum depth of 2 feet below ground surface, except in one area where excavation will extend to 3 feet below ground surface.
• Additional excavation of impacted soil from 36 tree wells to a depth of approximately one foot or a feasible depth that does not compromise the health of the trees. A geotextile barrier will be placed at the base of each tree well excavation prior to backfilling.
• Verification sampling of the excavation to confirm arsenic impacted soil has been removed.
• After confirmation sample results confirm the remedial goals, excavation areas will be graded or backfilled with clean fill material.
The SRP identifies best management practices designed to limit potential short-term risks (e.g., the exposure of students, staff, and onsite workers to AOCs during soil excavation activities) through the proper use of institutional controls, such as engineering controls, security measures, PPE, and adherence to established health and safety procedures, including the application of water spray to suppress fugitive dust emissions during the excavation, the proper handling, transportation and disposal of impacted soil, and enforcing speed limits at the Project site. The Soil Cleanup portion of the Classroom Replacement Project is estimated to cost approximately $910,640 and will therefore qualify for the Class 30 exemption.
County Clerk
Los Angeles
Attachments
Notice of Exemption
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