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PES Environmental, Inc. - Department of City Planningcityplanning.lacity.org/eir/LaBreaGateway/DEIR/Appendices/Appendix...On behalf of La Brea Gateway, LLC (LBG), PES Environmental,

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Page 1: PES Environmental, Inc. - Department of City Planningcityplanning.lacity.org/eir/LaBreaGateway/DEIR/Appendices/Appendix...On behalf of La Brea Gateway, LLC (LBG), PES Environmental,
Page 2: PES Environmental, Inc. - Department of City Planningcityplanning.lacity.org/eir/LaBreaGateway/DEIR/Appendices/Appendix...On behalf of La Brea Gateway, LLC (LBG), PES Environmental,

PES Environmental, Inc.

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TABLE OF CONTENTS

LIST OF TABLES..........................................................................................iv

LIST OF ILLUSTRATIONS .............................................................................iv

1.0 INTRODUCTION .....................................................................................1

2.0 BACKGROUND INFORMATION.................................................................2 2.1 Site Location and Description.....................................................................2 2.2 Proposed Site Redevelopment Plan ..............................................................2 2.3 Previous Investigations .............................................................................3

2.3.1 Soil Vapor.......................................................................................3 2.3.2 Soil ...............................................................................................3 2.3.3 Groundwater....................................................................................3

2.4 Remedial Objectives and Approach ..............................................................4

3.0 DESCRIPTION OF REMEDIATION ACTIVITIES ............................................4 3.1 Preliminary Activities ..............................................................................5

3.1.1 Permits and Plans ..............................................................................5 3.1.2 Utility Clearance ...............................................................................6 3.1.3 Building Survey ................................................................................6

3.2 Site Preparation......................................................................................6 3.3 Soil Excavation ......................................................................................6 3.4 Air Monitoring ......................................................................................8 3.5 Verification Soil Sampling Methodology and Analytical Program .........................9 3.6 Verification Soil Sample Results .................................................................9 3.7 HRC® Placement................................................................................... 10 3.8 Backfilling of Excavation Area ................................................................. 10 3.9 Asphalt Replacement ............................................................................. 10 3.10 Soil and Asphalt Characterization Results................................................... 11 3.11 Soil and Asphalt Transportation and Disposal .............................................. 11

4.0 SUMMARY AND CONCLUSIONS ............................................................. 11

5.0 REFERENCES ....................................................................................... 12 TABLES ILLUSTRATIONS

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TABLE OF CONTENTS (Continued)

APPENDICES A – RWQCB APPROVAL OF CORRECTIVE ACTION PLAN B – STORM WATER POLLUTION PREVENTION PLAN C – SCAQMD RULE 1166 VOC CONTAMINATED SOIL MITIGATION PLAN AND NOTIFICATION FORM D – CITY OF LOS ANGELES PERMITS E – WISS, JENNEY, ELSTNER ASSOCIATES, INC. SUMMARY OF FIELD OBSERVATIONS REPORT F – GEOTECHNOLOGIES, INC. NOTICE OF FIELD OBSERVATION REPORTS AND COMPACTION REPORT G – CITY OF LOS ANGELES DEPARTMENT OF BUILDING AND SAFETY INSPECTION REPORTS H – SCAQMD RULE 1166 MONITORING FORMS SUBMISSION I – LABORATORY ANALYTICAL REPORTS AND CHAIN OF CUSTODY DOCUMENTATION

J – SOIL AND ASPHALT REMOVAL DOCUMENTATION K – IMPORTED FILL AND ASPHALT DOCUMENTATION DISTRIBUTION

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LIST OF TABLES

Table 1 Summary of Verification Soil Sample Analytical Results

LIST OF ILLUSTRATIONS Plate 1 Site Location Map Plate 2 Site Plan and Area of Soil Remediation Plate 3 Limits of Excavation and Results of Verification Soil Sampling Plate 4-6 Site Photographs

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1.0 INTRODUCTION On behalf of La Brea Gateway, LLC (LBG), PES Environmental, Inc. (PES) has prepared this Corrective Action Completion Report for the former KCOP television production studios located at 915 North La Brea Avenue in Los Angeles, California (Site). The Site is located at the northwest corner of the intersection of North La Brea and Willoughby Avenues (Plate 1). The corrective action activities were for remediation of volatile organic compounds (VOCs) in accordance with PES’ documents Corrective Action Plan, Former KCOP Production Studios, 915 La Brea Avenue, Los Angeles, California dated June 3, 2005 (CAP) and Corrective Action Plan Addendum, Former KCOP Production Studios, 915 La Brea Avenue, Los Angeles, California, SLIC No. 1176, Site ID No. 2040175 dated August 31, 2005 (CAP Addendum). The CAP and the CAP Addendum were approved by the Regional Water Quality Control Board – Los Angeles Region (RWQCB) in a letter dated September 2, 2005. A copy of the RWQCB approval letter is included in Appendix A. This report summarizes the corrective actions performed in accordance with the CAP and CAP Addendum, and presents the results of verification soil sampling and waste management activities. This report also provides a brief overview of previous investigations conducted at the former KCOP Production Studios. A more detailed discussion of the previous investigations is presented in the CAP (PES, 2005a) and previous investigation reports (PES, 2005c; URS 2003a, 2003b and 2004). Groundwater monitoring was conducted at the Site during the Fourth Quarter of 2005 in accordance with a request from RWQCB staff. The methods and results of the groundwater monitoring were documented in a report dated January 12, 2006 prepared by PES. The report was also submitted to the RWQCB. In a letter dated January 10, 2006, RWQCB staff authorized LBG to discontinue groundwater monitoring at the Site beginning in 2006. The RWQCB directed Mole Richardson Company to complete delineation of groundwater contamination and, as such, has requested that the groundwater monitoring wells at the Site be maintained (RWQCB, 2006). Therefore, the Fourth Quarter 2005 groundwater monitoring event represents the last groundwater monitoring event to be conducted by LBG for the Site. In their letter dated September 2, 2005, RWQCB staff requested that a Human Health Risk Assessment (HHRA) be prepared and submitted to the RWQCB and Office of Environmental Health Hazard Assessment (OEHHA) prior to redevelopment on the Site. On behalf of LBG, PES submitted a draft HHRA dated February 6, 2006 to the RWQCB and OEHHA. Comments from RWQCB and OEHHA regarding the draft HHRA are pending. In accordance with the CAP Addendum, future soil samples will be collected for chemical analysis from beneath a transformer located on the Site. The concrete pad and soil beneath the transformer will be removed as part of site redevelopment activities. One soil sample from beneath the Site transformer will be collected and analyzed for polychlorinated biphenyls (PCBs) at the time of transformer removal. RWQCB staff will be notified prior to the time the work is to commence and PES will be on-Site to observe soil conditions and conduct soil

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sampling activities. This sampling is not related to the remediation activities reported herein and will be reported to RWQCB under separate cover. 2.0 BACKGROUND INFORMATION 2.1 Site Location and Description The Site is located at an elevation of approximately 270 feet above mean sea level (msl) at the northwest corner of the intersection of La Brea Avenue and Willoughby Avenue (Plate 1). The Site includes an alleyway that runs from the middle of the property to Romaine Street, north of the Site. The Site plan is presented on Plate 2. According to LBG, the Site covers approximately 2.27 acres and currently contains an approximately 30,336 square foot office and studio building (915 North La Brea Avenue) and an approximately 13,930 square foot office building (7169 Willoughby Avenue). According to a September 4, 2003 Phase I Environmental Site Assessment (ESA) by URS Corporation (URS), the buildings at 915 North La Brea Avenue and 7169 Willoughby Avenue were constructed in 1948 and 1946, respectively (URS, 2003b). Paved parking areas are present around the Site structures. PES understands that KCOP began operating a television studio on the Site in 1947. According to an ALTA survey of the Site (Iacobellis & Associates, Inc. 2004), a City of Los Angeles storm drain and associated storm drain easement are located beneath the Site alleyway and southeast corner of the Site. The storm drain easement is 12 feet wide and traverses the Site from northeast to southwest. The storm drain pipe is approximately 5.5 feet in diameter, and the depth to the top of storm drain in the alleyway is approximately 3.5 feet below ground surface (bgs). The URS ESA indicated that there was one property (the Mole-Richardson Company at 937 North Sycamore Avenue, located approximately 1/8-mile northeast of the Site) listed on the RWQCB Spills, Leaks, Investigations, and Cleanups (SLIC) database of properties affected by VOCs. Groundwater at the Mole-Richardson Company property (SLIC Case No. 679) has been impacted by VOCs. 2.2 Proposed Site Redevelopment Plan LBG acquired the Site in approximately September 2004 and intends to demolish the existing Site structures and develop a mixed-use commercial/residential complex. The complex will include subterranean parking to approximately 10 to 14 feet bgs as well as above-grade parking, above-grade retail and residential apartment units. The retail component is proposed as single-level ground floor leased spaces. Apartment units will be developed in two separate structures above the retail and parking structures. No redevelopment, with the exception of re-paving, is planned for the Site alleyway.

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2.3 Previous Investigations Several subsurface remedial investigations have been performed by PES and URS. The investigations included the collection and analysis of soil, groundwater and soil vapor samples. Analytical results from the investigations are summarized in PES’ Site Assessment Report dated March 10, 2005. The sections below present a summary discussion of the findings of the site assessment with regards to chemicals of concern found in environmental media. 2.3.1 Soil Vapor Results from the soil vapor survey indicated that the majority of the subject property was not underlain by soil vapor affected by VOCs. Tetrachloroethylene (PCE) was detected in soil gas samples collected from the southern end of the Site alleyway and in the southeastern corner of the Site. Results indicated that PCE-affected soil gas was limited in lateral extent in the alleyway. Vertical profiling indicated no significant flux of PCE or other VOCs from underlying PCE-affected groundwater into soil gas. Soil in the vicinity of the soil vapor detections outside of the alleyway will be removed to a depth of approximately 10 to 14 feet bgs during Site redevelopment to construct the subterranean parking garage, and was therefore not considered to pose a concern to the proposed Site development. PCE-affected soil vapor in sampling locations present within VOC-affected soil within the Site alleyway, was remediated as part of the corrective action. 2.3.2 Soil PCE was detected in soil in the alleyway at concentrations greater than the target soil cleanup levels developed in the CAP and CAP Addendum. Soil within the alleyway was remediated as part of the proposed corrective action activities. Soil samples collected from the southeastern portion of the property did not indicate significant concentrations of VOCs in soil. VOC detections were generally isolated to samples collected at 20 feet bgs, within the capillary fringe of underlying groundwater or present below the water table. The soil in this area had likely been impacted by VOC-affected groundwater flowing beneath the Site from off-site upgradient sources (i.e., Mole-Richardson). 2.3.3 Groundwater VOCs were detected in groundwater beneath the Site and Site vicinity at most sampling locations. Analytical results indicated groundwater had been minimally affected by PCE-affected soil located within the alleyway. The highest concentrations of PCE detected in groundwater were from sampling locations in the vicinity of the southeastern corner of the Site. These locations are downgradient of an off-Site RWQCB SLIC case site. Significant concentrations of PCE have been detected in groundwater at the Mole-Richardson Company property located at 937 Sycamore Avenue (SLIC No. 679), located approximately 1/8-mile

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northeast of the Site. It appears this facility is the primary source of dissolved PCE in groundwater identified at the Site. 2.4 Remedial Objectives and Approach As described above, soil analysis conducted indicated that soil beneath the Site alleyway contained localized VOCs, primarily PCE, and low concentrations of PCE degradation products. On the basis of the previous investigations, the CAP and CAP Addendum were prepared to: (1) identify and justify target soil cleanup goals for PCE and its degradation products; and (2) describe the procedures to implement the remedial activities. The objective of the corrective action at the Site was to remove VOC-affected soil that was present in the alleyway at concentrations exceeding target soil cleanup goals. Soil cleanup goals focused on PCE, as this was the only VOC detected above its associated ESL and PRG. However, soil cleanup goals were also determined for PCE degradation products trichloroethylene (TCE), cis-1,2-dichloroethylene (cis-1,2-DCE) and vinyl chloride. The target soil cleanup concentrations presented in the RWQCB-approved CAP Addendum were as follows: PCE at 195 µg/kg; TCE at 22.4 µg/kg; cis-1,2-DCE at 10.7 µg/kg; and vinyl chloride at 14.6 µg/kg. RWQCB subsequently approved the cleanup target levels (Appendix A). Remediation proposed in the CAP to achieve the remedial objectives included the excavation of a portion of the Site alleyway in three phases due to three target depths (8, 13 and 16 feet bgs total depth). The proposed excavation area had dimensions of approximately 16 to 20 feet wide, by 61 feet long for a total area of approximately 1,100 square feet. For each phase, once excavation activities were completed and verification soil samples confirmed that target cleanup goals had been achieved, backfill material would be placed into the excavation and compacted. To facilitate ongoing natural degradation of VOCs in groundwater beneath the Site, prior to placement of backfill materials in the proposed 16-foot deep excavation, Hydrogen Releasing Compound (HRC®) was to be placed at the bottom of the excavation. The CAP proposed the placement of HRC® as an additional protective measure, a biological (i.e., bacterial degradation of VOCs) enhancer, to facilitate ongoing natural degradation of VOCs in groundwater beneath the Site. 3.0 DESCRIPTION OF REMEDIATION ACTIVITIES Soil excavation was conducted at the former KCOP facility to remove VOC-affected soil containing VOC concentrations exceeding the target soil cleanup goals. LBG contracted with Marcor Remediation, Inc. (Marcor) of Cerritos, California to perform soil excavation and backfilling activities. The work was conducted between December 5 and 30, 2005. Photographs are provided on Plates 4 through 6. PES was present during the remediation to:

Page 9: PES Environmental, Inc. - Department of City Planningcityplanning.lacity.org/eir/LaBreaGateway/DEIR/Appendices/Appendix...On behalf of La Brea Gateway, LLC (LBG), PES Environmental,

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(1) observe and document the remedial activities; (2) conduct air monitoring; (3) collect verification soil samples from the excavation sidewalls and bottoms; (4) collect samples from excavated soil and asphalt for waste characterization purposes; and (5) document that the work was conducted in accordance with the CAP and CAP Addendum. Remedial activities conducted consisted of: (1) acquiring necessary permits; (2) preparing health and safety plans; (3) clearing the excavation area of underground utilities; (4) removing asphalt from areas above the impacted soil; (5) excavating soil within the Site alleyway containing VOC concentrations that exceeded the RWQCB-approved target soil cleanup goals; (6) collecting and analyzing verification soil samples from the limits of the excavation to verify the target cleanup concentrations were met; (7) collecting and analyzing waste characterization samples of the asphalt and excavated soil for off-Site recycling and disposal; (8) placing HRC® at the bottom of the deepest excavation once the limits of the excavation had been reached; and (9) backfilling and resurfacing the excavation. These activities are described in the following sections. 3.1 Preliminary Activities 3.1.1 Permits and Plans Marcor prepared a separate Site-specific health and safety plan for their work prior to the start of remediation activities to comply with Occupational Safety and Health Administration (OSHA), Title 29 CFR 1910.120 and California OSHA Title 8 GISO 5192. Additionally, PES’ existing Site-specific Health and Safety Plan (HSP) was updated by PES prior to conducting the remediation (PES, 2005d). In accordance with the CAP Addendum, Marcor prepared a Storm Water Pollution Prevention Plan (SWPPP) prior to the start of excavation activities. Work activities were performed in accordance with the SWPPP. A copy of the completed SWPPP is included in Appendix B. Pursuant to the South Coast Air Quality Management District (SCAQMD) Rule 1166, a VOC Contaminated Soil Mitigation Plan (VCSMP) was acquired by Marcor prior to excavation activities. As the estimated volume of the proposed soil excavation was less than 2,000 cubic yards, the VCSMP was a Various Locations plan. The VCSMP was issued by SCAQMD on August 10, 2005. A copy of the VCSMP is provided in Appendix C. Per the VCSMP, the SCAQMD was notified at least 24 hours prior to the start of excavation activities. The faxed and approved notification form is included in Appendix C. Prior to conducting excavation activities, Marcor acquired permits from the City of Los Angeles Department of Building and Safety (LADBS) for grading and for shoring. Marcor also acquired a permit from City of Los Angeles Department of Public Works Bureau of Engineering to work within the storm drain easement. Copies of the permits are provided in Appendix D.

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3.1.2 Utility Clearance An underground utility service locator was hired by Marcor to clear the proposed excavation of subsurface utilities. In addition, Underground Service Alert was contacted to schedule visits by public and private utility companies. Due to the location of a storm drain and easement across the northern third of the excavation area, the City of Los Angeles Department of Public Works, Bureau of Engineering (LABE) was also contacted prior to initiating excavation activities. 3.1.3 Building Survey Due to a single-story warehouse structure at 924 North Formosa Avenue, located immediately adjacent to the west of the alleyway excavation (Plates 2 and 3), Wiss, Janney, Elstner Associates, Inc. (WJE), a structural engineering firm, conducted pre-excavation and post-excavation surveys of the structure. The purpose of the surveys was to visually observe and document the east wall of the warehouse building prior to excavation and again upon completion of the work, and assess whether the excavation and backfilling process resulted in any significant damage to the warehouse building. WJE performed the pre-excavation survey of the east wall of the warehouse building on December 5, 2005, prior to the start of excavation. WJE conducted the post-excavation survey of the east wall of the warehouse building on January 4, 2006, upon completion of the remedial activities (including asphalt replacement). The WJE report concluded that the excavation and backfilling in the KCOP alleyway did not result in any significant damage or distress to the warehouse building. A copy of the WJE report is included in Appendix E. 3.2 Site Preparation Prior to the start of excavation activities, Marcor bermed the paved areas south and southwest of the excavation area with sandbags in accordance with the SWPPP. Temporary fencing was placed at all entry points to the excavation work area. Asphalt in the area of the excavation was removed by Marcor on December 5 and 6, 2005. The asphalt was temporarily stockpiled on plastic sheeting in a bermed area of the southwestern corner of the parking lot. 3.3 Soil Excavation Soil containing VOC concentrations in excess of the target cleanup concentration was excavated between December 5 and December 27, 2005. The final limits of the excavation and verification soil sampling locations are presented on Plate 3. Photographs of the soil remediation activities are presented on Plates 4 through 6. On December 5, 2005, a test pit was excavated to assess soil VOC concentrations at the northern limit of the northern excavation area. Two soil samples were collected at 4 feet bgs.

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The first (SN-A) was collected at the proposed northern boundary of the excavation area. A second sample (SN-B) was collected approximately 3 feet to the north of SN-A to be analyzed only if required. PCE was detected in SN-A at a concentration of 26 µg/kg, below the clean-up goal of 195 µg/kg; therefore, SN-B was not analyzed. The excavation was conducted in three stages: the southern excavation area was excavated first to a depth of 8 feet bgs; next the middle excavation area was excavated to a depth of 13.5 feet bgs; and lastly, the northern excavation area was excavated last to a depth of 13 feet bgs. The final limits of the excavation are presented on Plate 3. The excavation was conducted using a track-mounted excavator, a track-mounted Bobcat and a mini front-end loader. Excavated soil was placed on, and covered with, plastic sheeting in the southwestern parking area on the Site. In order to protect the structural integrity of the adjacent warehouse building, shoring was used during all excavation activities. Slide rail shoring was used to temporarily shore the sidewalls of each stage of the excavation. A letter dated April 27, 2005 from Geotechnologies Inc., a geotechnical firm, presenting their evaluation and approval of the proposed slide-rail shoring method was included with the CAP. Throughout the excavation activities, Geotechnologies made daily inspections of both the shoring installation and the excavation progress. Geotechnologies made recommendations concerning the shoring placement and support, inspected the excavation bottom, and inspected and conducted nuclear gauge density tests of the compacted backfill. Daily Notice of Field Observation reports and the Compaction Report prepared by Geotechnologies are included in Appendix F. Once the bottom of an excavation had been reached and verification samples confirmed that target soil cleanup goals had been met, the LADBS was contacted to arrange for an inspection. Prior to placement of any backfill into the excavation, the LADBS inspector inspected and approved the excavation bottom. The LADBS inspection report is included as Appendix G. Soil excavation activities commenced on December 6, 2005, at the southern excavation area to 8 feet bgs. Verification soil samples were collected from the eastern, western and southern sidewalls at 4 feet bgs and the excavation bottom at 8 feet bgs to verify that target cleanup goals had been met. Once the excavation bottom was approved by the LADBS inspector, the excavation was backfilled and the southern, western and eastern shoring panels were removed. The northern shoring panel was left in place to serve as the southern panel for the middle excavation area. According to the CAP, the middle excavation area was to be excavated to 16 feet bgs. Groundwater beneath the Site is under confined conditions and first encountered at 19 feet bgs (PES, 2005a). The excavation was, therefore, not to exceed more than 3 feet above first-encountered groundwater (i.e., not to extend deeper than 16 feet bgs). However, during excavation activities conducted in the middle excavation area, groundwater was observed at 14 feet bgs. Soil was placed back into the area where groundwater was observed and

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excavation activities were halted at 13.5 feet bgs. A verification sample was collected from the excavation bottom at 13.5 feet bgs. In order to address a concentration of PCE at 340 µg/kg in a sample collected at 15 feet bgs in the area of the middle excavation during the PES site assessment investigation (PES, 2005c), soil was removed in the approximate area of the sample to a depth of 15 feet bgs (Plate 4). Clean fill was immediately placed back into the excavation in this area. Prior to placement and compaction of backfill material in the middle excavation area, HRC® was placed on the excavation bottom. Details of the HRC® placement are presented in Section 3.6, below. Once the bottom of the excavation area was inspected and approved fro backfilling by the LADBS inspector, the excavation was backfilled and the eastern, western and southern shoring panels were removed. The northern shoring panel was left in place to serve as the southern panel for the northern excavation area. The third, northern excavation area was to a depth of 13 feet bgs. Initially, the top of the storm drain pipe that traverses the excavation area was exposed in order to confirm the location and depth of the pipe. The excavation remediation activities were conducted to the north and south of the storm drain. In accordance with the CAP, to protect the pipe, no soil from beneath the storm drain pipe was removed during excavation activities. The initial western sidewall verification sample (SNW-4) indicated PCE-affected soil was still present at concentrations in excess of the clean-up goal. An approximate additional 3 to 5 inches of soil was removed from the entire western sidewall. A verification sample collected from the new sidewall surface (SNW-4B) indicated target soil clean-up goals had been met. 3.4 Air Monitoring In accordance with the VCSMP and the HSP, air monitoring was conducted during soil excavation and handling activities. A photoionization detector (PID) was used to conduct the monitoring. Monitoring was conducted at a minimum frequency of one reading every 15 minutes at the soil excavation or at the soil stockpile during soil handling activities. In accordance with SCAQMD requirements: (1) the PID was calibrated daily using the procedures specified by the manufacturer; (2) each reading was correlated to and expressed as hexane, using a conversion factor supplied by the PID manufacturer; and (3) readings were recorded on an SCAQMD-approved form. The completed forms are included in Appendix H. No readings requiring notification of the SCAQMD (50 parts per million by volume (ppmv) or greater) were detected. In accordance with the VCSMP, Marcor provided a written report to SCAQMD within 30 days of project completion. The submission letter is included in Appendix H.

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3.5 Verification Soil Sampling Methodology and Analytical Program Verification soil samples were collected from the excavation for chemical analyses. To verify attainment of target cleanup goals, soil sampling and laboratory analyses were conducted in accordance with the Verification and Sampling Plan (VSAP) in the CAP. If target soil cleanup goals were exceeded in a verification sample, further excavation was conducted until the VOC concentration in a subsequent verification sample was less than the target soil cleanup goals. The verification sample locations are shown on Plate 3. The results of the verification soil sampling are presented in Table 1 and laboratory analytical reports are presented in Appendix I. In accordance with the VSAP, verification soil samples were collected directly from the sidewalls of the excavation at a frequency of one sample per north/south sidewall and three samples per east/west sidewall. Sidewall samples were collected at a depth of 4 feet bgs. Excavation bottom samples were collected at a frequency of one discrete sample for approximately every 20-foot by 20-foot area, or for every 400 square feet of excavation bottom when the area was not square. A total of 13 verification samples were collected: three from the excavation bottom, nine from the excavation sidewalls, and one from the northern test pit. These samples were collected on December 5, 6, 7, 12, 13, 19, 21, and 23, 2005. Chain of custody forms are included in Appendix I. Sample collection and laboratory analyses were conducted in accordance with U.S. EPA Method 5035 for volatiles in soil. For each verification soil sample, three EnCore samplers were utilized. Each EnCore was utilized by pushing the sampler into the freshly exposed surface until the sampler was full. The sampler head was then cleaned and the sampler cap was tightly secured. The three samplers were placed into a resealable bag, labeled for identification with sample ID, and time and date collected, and placed in a chilled, thermally insulated cooler. The samples were delivered under chain-of-custody protocol to American Analytics of Chatsworth, California, a hazardous waste analytical laboratory that is certified by the California Department of Health Services. In accordance with U.S. EPA Method 5035, the soil samples were extracted by the analytical lab within 48 hours of collection. In accordance with the VSAP, verification soil samples were analyzed for PCE, TCE, cis-1,2-DCE, and vinyl chloride using U.S. EPA Test Method 8260B. In addition, one bottom and one sidewall verification sample, per the CAP Addendum, were analyzed for semi-volatile organic compounds (SVOCs) using U.S. EPA Test Method 8270C and for pesticides using U.S. EPA Test Method 8081A. 3.6 Verification Soil Sample Results Verification sample results are presented in Table 1. Results of the final verification samples are also presented on Plate 3. The laboratory analytical reports and chain of custody documentation are presented in Appendix I.

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As shown on Plate 3 and in Table 1, the target cleanup concentrations of 195 µg/kg PCE, 22.4 µg/kg TCE, 10.7 µg/kg cis-1,2-DCE and 14.6 µg/kg vinyl chloride were reached in all of the final verification samples collected from the bottom and sidewalls of the excavation areas. In addition, no SVOCs or pesticides were detected at or above their respective laboratory reporting limits in the verification soil samples collected from the excavation sidewall and bottom (Table 1 and Plate 3). 3.7 HRC® Placement Prior to placement of backfill materials, HRC® was placed at the bottom of the middle, 13.5-foot depth excavation. HRC® was placed as an additional protective measure, a biological (i.e., bacterial degradation of VOCs) enhancer, to facilitate ongoing natural degradation of VOCs in groundwater beneath the Site. HRC® was placed via direct applications to the excavation bottom on December 15, 2005. Approximately 118 pounds of HRC® (4 buckets) were applied to the excavation bottom prior to backfilling. The material was generally uniformly distributed across the bottom of the excavation. 3.8 Backfilling of Excavation Area The excavations were backfilled immediately following LADBS approval of the excavation bottoms. The excavation areas were backfilled using select imported fill material. The fill material was an imported crushed base rock. Documentation of the crushed base rock is presented in Appendix K. The backfill material was placed in lifts no greater than 12 inches thick and compacted using an excavator with a sheep’s foot roller attachment. The backfill was compacted to at least 95-percent of the maximum relative dry density. Geotechnologies conducted field density testing of the compacted fill. Copies of the field density test data are presented in Appendix F. The excavation was backfilled to within approximately 6 inches of the top of the existing asphalt pavement surface to allow construction of a replacement asphalt pavement surface (Section 3.9). 3.9 Asphalt Replacement After backfilling was completed, the asphalt surface was replaced to match existing asphalt thickness and grade. Hot-batch asphalt was placed by Asphalt Care, Inc., a subcontractor to Marcor, on December 30, 2005 to match the surface of the existing alleyway. The asphalt cap consisted of 2 inches of base rock, and 4 inches of asphalt. The asphalt was placed in two 2-inch thick lifts. A photograph of the replaced asphalt is shown on Plate 6, Photograph 2. Asphalt placement documentation is presented in Appendix K.

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3.10 Soil and Asphalt Characterization Results Soil excavated from the Site was stockpiled on, and covered by, plastic sheeting in the paved parking lot at the southwest corner of the Site (Plate 2). Excavated soil was characterized by collecting one soil sample for VOC analyses per approximately 100 cubic yards. The samples were collected directly from the soil stockpiles. The samples were collected by driving a pre-cleaned, 3-inch long stainless-steel tube into the soil. After soil collection, the ends were sealed with Teflon sheeting and covered with plastic end caps. Samples were labeled, handled and analyzed under the same protocol as the verification soil samples collected from the excavation. A total of five characterization soil samples were analyzed. PCE was detected in two of the five samples at concentrations of 11 and 2.3 µg/kg. TCE, cis-1,2-DCE and vinyl chloride were not detected at or above the laboratory reporting limits of 5 µg/kg. The laboratory analytical reports and chain of custody documentation are presented in Appendix I. Asphalt removed from the area of the excavation was stockpiled on plastic sheeting in the parking lot at the southwest corner of the Site. Two asphalt chip samples were collected from the stockpile for characterization purposes. Asphalt chips were collected from various locations within the stockpile and placed in pre-cleaned, glass jars. Samples were labeled, handled and analyzed under the same protocol as the verification soil samples collected from the excavation. A total of two characterization samples of the removed asphalt were collected and analyzed. PCE, TCE, cis-1,2-DCE and vinyl chloride were not detected at or above the laboratory reporting limits of 5 µg/kg in either of the samples. The laboratory analytical reports and chain of custody documentation are presented in Appendix I. 3.11 Soil and Asphalt Transportation and Disposal On December 20, 21, 28 and 29, 2005, the soil was transported to the Waste Management Inc.’s Lancaster Landfill in Lancaster, California, for disposal as non-hazardous waste. Approximately 635 tons of soil were transported to and disposed at the Lancaster landfill. Soil transportation and disposal documentation is included in Appendix J. Asphalt was transported off-Site by JPA Construction Clean-Up Services, Inc. on December 30, 2005. Approximately 40 cubic yards of asphalt were removed from the Site. Asphalt removal documentation is included in Appendix J. 4.0 SUMMARY AND CONCLUSIONS Corrective action has been successfully implemented in accordance with the RWQCB-approved CAP and CAP Addendum at the former KCOP Production Studios at 915 N. La Brea Avenue.

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Approximately 635 tons of PCE-affected soil was excavated to a maximum depth of approximately 13.5 feet below grade. On the basis of the results of the verification soil samples collected from the bottom and sidewalls of the excavation areas, soil with VOC concentrations exceeding the target soil cleanup goals has been removed from the Site. HRC was placed on the deepest portion of the excavation area to enhance biological degradation processes within the capillary fringe zone. The excavation has been backfilled with imported clean fill and the area of soil excavation has been capped with asphalt pavement. In accordance with a request from the RWQCB, additional soil sampling is to be conducted beneath an existing electrical transformer during redevelopment of the property. This future sampling is not related to the remediation activities reported herein and will be conducted as requested with the results reported to the RWQCB under separate cover. Accordingly, PES, on behalf of La Brea Gateway, LLC, requests a letter from the RWQCB stating that the remedial goals have been achieved and no further investigation or remedial action regarding is required at the Site. 5.0 REFERENCES California Environmental Protection Agency 2005. Use of California Human Health Screening

Levels (CHHSLs) in Evaluation of Contaminated Properties. January. California Regional Water Quality Control Board, 2005. Screening For Environmental

Concerns At Sites With Contaminated Soil and Groundwater (ESLs). February. California Regional Water Quality Control Board, Los Angeles Region, 2005. Approval of

Corrective Action Plan – Former KCOP Production Studios, 915 North La Brea Avenue, Los Angeles, California (SLIC No. 1176, Site ID No. 2040175). September 2.

California Regional Water Quality Control Board, Los Angeles Region, 2006. Approval of

Discontinuation of Groundwater Monitoring Request – Former KCOP Production Studios, 915 North La Brea Avenue, Los Angeles, California (SLIC No. 1176, Site ID No. 2040175). January 10.

Iacobellis & Associates, Inc. 2004. ALTA/ACSM Land Title Survey, 915 N La Brea Ave,

7169 W Willoughby Avenue. January 27. PES Environmental Inc., 2005a. Corrective Action Plan, Former KCOP Production Studios,

915 North La Brea Avenue, Los Angeles, California. June 3. PES Environmental Inc., 2005b. Corrective Action Plan Addendum, Former KCOP

Production Studios, 915 North La Brea Avenue, Los Angeles, California, SLIC No. 1176, Site ID No. 2040175. August 31.

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PES Environmental Inc., 2005c. Site Assessment Report, Former KCOP Production Studios,

915 North La Brea Avenue, Los Angeles, California. March 10. PES Environmental Inc., 2005d. Health and Safety Plan, Corrective Action Plan

Implementation, Former KCOP Production Studios, 915 North La Brea Avenue, Los Angeles, California. August 15.

PES Environmental Inc., 2005e. Groundwater Monitoring Report, Fourth Quarter 2005,

Former KCOP Production Studios, 915 North La Brea Avenue, Los Angeles, California. January 15.

PES Environmental Inc., 2006. Human Health Risk Assessment, Former KCOP Production

Studios, 915 North La Brea Avenue, Los Angeles, California. February 6. URS Corporation Americas, 2004. Summary Letter, Former KCOP Broadcast Facility,

915 La Brea Avenue, Los Angeles, California. July 20. URS Corporation, 2003a. Report, Limited Soil Sampling Investigation, Former KCOP

Broadcast Facility, 915 North La Brea Avenue, Los Angeles, California. August 28. URS Corporation, 2003b. Report, Phase I Environmental Site Assessment, Former KCOP

Broadcast Building, 915 North La Brea Avenue, Los Angeles, California. September 4. U.S. Environmental Protection Agency, 2004. Preliminary Remediation Goals (PRGs).

October.

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PES Environmental, Inc.

TABLE

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PES Environmental, Inc.

Sample Sample Sample Depth Sample

Identification Location (feet bgs) Date

Test pit SN-A northern boundary of excavation 4 12/5/2005 26 <5.0 <5.0 <5.0 NA NA

Southern Excavatio SS-A-4ft southern sidewall 4 12/6/2005 110 <5.0 <5.0 <5.0 NA NA

SSW-4 western sidewall 4 12/6/2005 140 <5.0 <5.0 <5.0 NA NA

SSE-4 eastern sidewall 4 12/7/2005 <5.0 <5.0 <5.0 <5.0 NA NA

BS-8 bottom of excavation 8 12/7/2005 14 <5.0 <5.0 <5.0 NA NA

Middle Excavation MSW-4 western sidewall 4 12/12/2005 100 <5.0 <5.0 <5.0 NA NA

MSE-4 eastern sidewall 4 12/12/2005 38 <5.0 <5.0 <5.0 NA NA

BS-13.5 bottom of excavation 13.5 12/13/2005 20 <5.0 <5.0 <5.0 NA NA

Northern Excavation SNE-4 eastern sidewall 4 12/19/2005 37 8.2 <5.0 <5.0 ALL ND ALL ND

SNN-4 northern sidewall 4 12/19/2005 24 <5.0 <5.0 <5.0 NA NA

SNW-4 western sidewall 4 12/19/2005 380 <5.0 <5.0 <5.0NA NA

Initial sidewall sample; sample does not represent final excavation conditions; an additional 3 to 5 inches of soil was removed from the sidewall and sample SNW-4B was collected.

SNW-4B western sidewall 4 12/23/2005 52 <5.0 <5.0 <5.0 NA NA Sample represents final sidewall excavation conditions.

BN-13 bottom of excavation 13 12/21/2005 7.4 <5.0 <5.0 <5.0 ALL ND ALL ND

Target Soil Cleanup Goal (µg/kg) 195 22.4 10.7 14.6 NA NA

Notes:feet bgs - feet below ground surfaceAnalytical results in micrograms per kilogram (µg/kg)Bold indicates compound detected at or above the indicated laboratory reporting limit<5.0 - compound not detected at or above the indicated laboratory reporting limitND - compounds not detected at or above their respective laboratory reporting limitsNA - not analyzedPCE - TetrachloroethyleneTCE - Trichloroethylenecis-1,2-DCE - cis-1,2-DichloroethyleneSVOCs - semi-volatile organic compoundsAll samples analyzed for volatile organic compounds by U.S. EPA laboratory method 8260B/5035Samples analyzed for pesticides by U.S. EPA laboratory method 8081ASamples analyzed for SVOCs by U.S. EPA laboratory method 8270C

Table 1Summary of Verification Soil Sample Analytical Results

Former KCOP Production StudiosLos Angeles, California

cis-1,2-DCE

Vinyl ChlorideExcavation CommentsPesticide

s SVOCsPCE TCE

24106002R007.xls - Table 1 2/13/2006

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PES Environmental, Inc.

ILLUSTRATIONS

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JOB NUMBER DRAWING NUMBER REVIEWED BY DATE

PLATE

241.060.02.016 2/06

4PES Environmental, Inc.Engineering & Environmental Services

Photo 2.View to northeast during excavation of northern excavation area.Note exposed concrete storm drain pipe and slide rail shoring system

Photo 1.View to northeast during excavation of southern excavation area.Note slide rail shoring system.

241-060-02016_photos

Site PhotographsFormer KCOP Production Studios915 North La Brea AvenueLos Angeles, California

KSF

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JOB NUMBER DRAWING NUMBER REVIEWED BY DATE

PLATE

5PES Environmental, Inc.Engineering & Environmental Services

Photo 2.Placement and compaction of backfill using sheeps foot roller on excavator.

Photo 1.View to southwest of northern excavation area.Note storm drain pipe, slide rail shoring systemand adjacent building (background).

Site PhotographsFormer KCOP Production Studios915 North La Brea AvenueLos Angeles, California

241.060.02.016 2/06241-060-02016_photos KSF

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JOB NUMBER DRAWING NUMBER REVIEWED BY DATE

PLATE

6PES Environmental, Inc.Engineering & Environmental Services

Photo 2.View to south of asphalt replacement in the excavation area.

Photo 1.View to north of excavation area backfilled to approximately 6 inchesbelow grade, prior to asphalt replacement.

Site PhotographsFormer KCOP Production Studios915 North La Brea AvenueLos Angeles, California

241.060.02.016 2/06241-060-02016_photos KSF

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PES Environmental, Inc.

APPENDIX A

RWQCB APPROVAL OF CORRECTIVE ACTION PLAN

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PES Environmental, Inc.

APPENDIX B

STORM WATER POLLUTION PREVENTION PLAN

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PES Environmental, Inc.

APPENDIX C

SCAQMD RULE 1166 SOIL MITIGATION PLAN AND NOTIFICATION FORM

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PES Environmental, Inc.

APPENDIX D

CITY OF LOS ANGELES PERMITS

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APPENDIX E

WISS, JANNEY, ELSTNER ASSOCIATES, INC. SUMMARY OF FIELD OBSERVATIONS REPORT

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Wiss, Janney, Elstner Associates, Inc. 2550 North Hollywood Way, Suite 500

Burbank, California 91505 818.303.1300 tel | 818.847.0051 fax

www.wje.com

23 January 2006 Kyle Flory PES Environmental 1682 Novato Blvd., Suite 100 Novato, CA 94947 Re: Summary of Field Observations 915 North La Brea Avenue Los Angeles, CA WJE Project No. 2005.3589.0 Dear Mr. Flory: At your request, Wiss, Janney, Elstner Associates, Inc. (WJE) performed visual observations of an existing concrete and masonry warehouse building located adjacent to the former KCOP Production Studios at 915 North La Brea Avenue, Los Angeles, California. Contaminated soil in the alley adjacent to the warehouse building was removed and replaced, requiring excavation directly adjacent to the building. WJE visually observed the warehouse building on 5 December 2005, prior to the start of excavation, and again on 4 January 2006, upon completion of backfilling. The purpose was to visually observe the building prior to excavation and again upon completion of the work, and report on whether the excavation and backfilling process resulted in any significant damage to the warehouse building. Warehouse Building Description We did not verify the age of the building, however, it appears to be 40 or more years old. The alley finish grade slopes; the warehouse floor is approximately two to four feet higher in elevation than the alley. Below the level of the warehouse floor, the exterior walls are exposed, cast-in-place concrete stem walls; above the floor level the exterior walls are concrete block (Figure 1). Information regarding the building foundations was not available for our review; however, the foundations likely consist of shallow, continuous wall footings. Excavation and Backfill Procedures The excavation occurred along the east side of the warehouse building and was performed in one continuous operation, in three segments of varying depth. The total length of the excavation was approximately 61 feet; with the northern edge of the excavation starting approximately 13 feet south of

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the northeast corner of the building. The following table summarizes the length and depth of the excavation segments, starting from the northern edge of the excavation.

Segment Length Depth

1 29 feet 13 feet 2 16 feet 13.5 feet 3 16 feet 8 feet

The alley adjacent to the warehouse building was excavated to the dimensions indicated above to remove the identified, contaminated soils. The entire excavation was shored using a “slide-rail” shoring system installed as the excavation progressed. Upon completion of the excavation, the excavation was then backfilled and compacted with engineered fill, with the shoring system pulled as the backfilling progressed. Observations and Conclusions Based on our visual observations, the condition of the warehouse building following the excavation and backfilling appears to be consistent with the condition prior to the excavation. We did not observe any significant, additional cracking or evidence of building settlement or movement related to the excavation and backfilling procedures. It is our opinion that the excavation and backfilling did not result in any significant damage or distress to the warehouse building. We appreciate the opportunity to assist you with this project. Should you have any questions concerning this report or wish to discuss it further, please call me. Very truly yours, WISS, JANNEY, ELSTNER ASSOCIATES, INC.

James C. Pan, P.E. C63496 Project Manager

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Figure 1 - Exterior elevation of adjacent building

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PES Environmental, Inc.

APPENDIX F

GEOTECHNOLOGIES, INC. NOTICE OF FIELD OBSERVATION REPORTS

AND COMPACTION REPORT

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PES Environmental, Inc.

APPENDIX G

CITY OF LOS ANGELES DEPARTMENT OF BUILDING AND SAFETY INSPECTION REPORTS

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