New School Site Preliminary Environmental Assessment

Padre prepared a Preliminary Environmental Assessment (PEA) for a proposed new 30-classroom elementary school proposed to be located in Gilroy, California (Project Site). The PEA was conducted in accordance with a Preliminary Environmental Assessment Work Plan, also prepared by Padre and approved by the California Environmental Protection Agency Department of Toxic Substances Control (CalEPA/DTSC). The activities performed were to fulfill the requirements of an Environmental Oversight Agreement issued to the school district by CalEPA/DTSC. Pursuant to Option A of the California Education Code Section 17213.1.a (6) (A), the PEA was made available to the public for review and comment.

The purpose of the PEA was to establish whether a release or potential release of hazardous substances or naturally occurring material, which would pose a threat to human health via ingestion, dermal contact, and inhalation exposure pathways, exists at the Project Site. Chemicals of potential concern (COPCs) identified at the Project Site included:

• Organochlorine pesticides (OCPs) in soil from historic agricultural use;
• Arsenic and copper in soil from historic agricultural use;
• Cobalt in soil related to concentrations identified in a soil stockpile located on the Project Site; and
• Naturally occurring asbestos (NOA) from weathering of ultramafic rock outcrops located in outlying areas.

Analytical results from soil sampling indicate that the amounts of the COPCs identified above are not present in on-site soils at levels that require further assessment or remediation, based upon State of California health risk thresholds with the exception of NOA.

Padre prepared a Removal Action Work Plan (RAW) and Operations and Maintenance (O&M) Plan for the Project Site. The recommended response action to eliminate, reduce, and/or mitigate the identified chemicals of concern is the implementation of engineering controls in the form of a “cap” placed over the NOA-containing soil, creating a barrier to prevent or greatly reduce human exposure and health impacts. After school construction is completed, the O&M Plan will address long-term monitoring and maintenance of engineering controls, and management of soils containing elevated concentrations of NOA at the Project Site.