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February 28, 2006 Project No. 10181 Robert Nowak Century City Realty LLC 10250 Constellation Boulevard Suite 1650 Los Angeles, California 90067 Subject: Current Site Conditions and Evaluation of Potential Public Health Impacts 10131 Constellation Blvd. Los Angeles, California Dear Mr. Nowak: On the behalf of Century City Realty LLC, Geomatrix Consultants, Inc. (Geomatrix), has prepared this letter report documenting the current soil conditions at 10131 Constellation Boulevard in Los Angeles, California (the site, Figure 1), and the potential for health effects associated with future use of the site. The scope of work for this investigation was developed following the review of the closure report by Law/Crandall, Inc. (1991). The soil data were compared to California Human Health Screening Levels (CHHSLs) as set forth by the California Environmental Protection Agency (Cal-EPA, 2005a) as a preliminary means of determining the possible significance of residual chemicals at the site with respect to exposure scenarios reasonably foreseeable at the site. Other analogous screening criteria (e.g., Preliminary Remediation Goals [PRGs] as established by Region 9 of the U.S. Environmental Protection Agency [U.S. EPA]) were used for chemicals not having a CHHSL. It is our understanding that future construction activities represent the only time during which exposure to site soils will be reasonably anticipated and screening levels were chosen accordingly, although criteria for residential scenarios were also consulted. CHHSLs and PRGs are calculated concentrations of residual chemicals in soil that would not result in adverse health effects with a substantial margin of safety and are available for both residential and occupational (construction) exposures. CHHSLs are issued by Cal- EPA, derived with Cal-EPA toxicity criteria, and specifically intended for use in California; accordingly, the use of CHHSLs was favored for this assessment and U.S. EPA PRGs were used as a secondary source of screening criteria only for chemicals which did not have a CHHSL. In all cases, the CHHSLs for commercial/industrial land use were chosen for use as the comparative benchmarks in this assessment, as the use of these values is consistent with the foreseeable exposure scenarios anticipated at the site. CHHSLs and PRGs are screening-type criteria which incorporate conservative assumptions regarding potential receptor contact with soil chemicals, including direct contact. These assumptions purposefully exaggerate likely actual exposures. For arsenic, the published

Transcript of Century City Realty L

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February 28, 2006 Project No. 10181

Robert Nowak Century City Realty LLC 10250 Constellation Boulevard Suite 1650 Los Angeles, California 90067

Subject: Current Site Conditions and Evaluation of Potential Public Health Impacts 10131 Constellation Blvd. Los Angeles, California

Dear Mr. Nowak:

On the behalf of Century City Realty LLC, Geomatrix Consultants, Inc. (Geomatrix), has prepared this letter report documenting the current soil conditions at 10131 Constellation Boulevard in Los Angeles, California (the site, Figure 1), and the potential for health effects associated with future use of the site. The scope of work for this investigation was developed following the review of the closure report by Law/Crandall, Inc. (1991). The soil data were compared to California Human Health Screening Levels (CHHSLs) as set forth by the California Environmental Protection Agency (Cal-EPA, 2005a) as a preliminary means of determining the possible significance of residual chemicals at the site with respect to exposure scenarios reasonably foreseeable at the site. Other analogous screening criteria (e.g., Preliminary Remediation Goals [PRGs] as established by Region 9 of the U.S. Environmental Protection Agency [U.S. EPA]) were used for chemicals not having a CHHSL. It is our understanding that future construction activities represent the only time during which exposure to site soils will be reasonably anticipated and screening levels were chosen accordingly, although criteria for residential scenarios were also consulted.

CHHSLs and PRGs are calculated concentrations of residual chemicals in soil that would not result in adverse health effects with a substantial margin of safety and are available for both residential and occupational (construction) exposures. CHHSLs are issued by Cal-EPA, derived with Cal-EPA toxicity criteria, and specifically intended for use in California; accordingly, the use of CHHSLs was favored for this assessment and U.S. EPA PRGs were used as a secondary source of screening criteria only for chemicals which did not have a CHHSL. In all cases, the CHHSLs for commercial/industrial land use were chosen for use as the comparative benchmarks in this assessment, as the use of these values is consistent with the foreseeable exposure scenarios anticipated at the site.

CHHSLs and PRGs are screening-type criteria which incorporate conservative assumptions regarding potential receptor contact with soil chemicals, including direct contact. These assumptions purposefully exaggerate likely actual exposures. For arsenic, the published

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CHHSLs (and PRGs) are so stringent due to default assumptions regarding potential health effects that they are often unattainable and not in concert with background, everyday exposures to arsenic from a variety of sources; therefore, the initial evaluation of soil concentrations of arsenic is typically based on the comparison to natural background concentrations. Other metals that occur naturally in soils were also evaluated based on a comparison to background soil concentrations for California, where these data were available.

As detailed below, the available information on current site conditions, reasonably anticipated precautions taken during the construction phase and the potential for human exposures to residual chemicals in soil strongly support that there will be no significant health risks to either workers during or after the construction phase or residents of the completed project. This report presents brief background information, a summary of the previous investigation, and results of this evaluation.

BACKGROUND The site is currently a 5.5-acre largely vacant parcel. An approximate 39,000 square foot area within the site is devoted to commercial and restaurant uses. The proposed development includes the excavation and construction of a four-level, below-ground parking structure, two 47-story residential towers, and a 12-story residential loft building, which will be on top of the parking structure in combination with some open space.

The site was formerly an oil and gas producing drill site owned and operated by Chevron U.S.A., Inc. (Chevron). Removal of the surface facilities and underground pipelines began in late August 1990 (Law/Crandall, 1991).

During Chevron’s investigations, the site was divided into three conceptual areas (Figure 1).

1. Bermed Area, which is the former tank and gas scrubber area located at the southeastern portion of the site. This area once contained natural gas scrubbers and four 1000-gallon and three 500-gallon above-ground storage tanks.

2. Production Facilities Area, which is the former gas compression and processing facilities, located at the eastern portion of the site (north and northwest of the bermed area).

3. Former Well Vault Area, which contained the producing wells located at the western portion of the site.

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ENVIRONMENTAL SCREENING LEVELS Cal-EPA CHHSLs are screening tools for determining the significance of chemical concentrations in soil, and defined to be protective of very high-end levels of exposure, while still consistent with the exposure pathways and receptors identified for a site. CHHSLs are based upon methodologies used by the U.S. EPA Region 9 (U.S. EPA, 2004) to develop PRGs, and both consider direct contact exposures to soil contaminants (dermal contact, incidental ingestion, and inhalation of dusts) as potential exposure pathways. CHHSLs use Cal-EPA toxicity criteria (e.g., cancer potency factors) where available which are, in general, more restrictive than U.S. EPA toxicity criteria (Cal-EPA, 2005a). Screening levels used in this assessment were chosen from the CHHSL or PRG values developed for commercial/industrial land use, as these values are protective of exposures anticipated for the only foreseeable receptors of concern (construction workers) at the site. Despite the fact that the planned development at this site includes residential buildings, these high-rise structures are not the types of dwellings that would give rise to the types of exposures typically represented in a conceptual site model for residential scenarios1. In other words, based on the design and construction elements of these residential buildings, little, if any, opportunity for contact with site soils could be anticipated. Therefore, regulatory values, such as CHHSLs or PRGs derived based on a residential exposure scenario have no relevance to our assessment for non-volatile soil contaminants2.

The commercial/industrial land use CHHSLs (or PRGs) consider workers as the “receptors” of concern and are derived using parameters for adults only (not children) and assume contact frequencies that are more appropriate for an occupational scenario. CHHSLs are calculated based on a target risk of 1 × 10-6 (one-in-one-million) for chemicals with carcinogenic health effects and a target hazard index of 0.1 for chemicals with noncarcinogenic health effects. The exceedance of a CHHSL does not necessarily indicate that adverse health effects will occur, but suggests that additional evaluation of the potential risks including the incorporation of a more refined evaluation of exposure is warranted. The screening levels used for the initial evaluation of each chemical analyte (CHHSLs, U.S. EPA PRGs, or ESLs) are presented in Table 1 – 4 and the basis for using these criteria is described below.

1 Residential CHHSLs are intended to be protective of residents (based on a typical house constructed for a single-family dwelling) who might be exposed to chemicals in soils on a regular basis via ingestion, dermal contact, and inhalation of suspended particulates. 2 The impact of using residential rather than occupational screening criteria on the conclusions of this analysis will be discussed as appropriate in the body of the report.

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The CHHSL for arsenic (applicable to occupational exposure scenarios) is 0.24 milligrams per kilogram (mg/kg). This criterion is lower than typical background levels of arsenic in soil in the State of California. For this reason, some agencies have adopted screening levels for arsenic based on normal background levels for the area. For example, the San Francisco Bay Regional Water Quality Control Board (RWQCB) has developed an Environmental Screening Level (ESL) of 5.5 mg/kg for arsenic, derived from background concentrations measured in Northern California.3 A regulatory program for assessing the soil arsenic background levels at school sites within Los Angeles County has also relied on the comparisonto natural background levels (Cal-EPA, 2005b). Thus, approaches using some type of comparison to background levels is becoming a widely-accepted practice in the screening of soil data for arsenic, and is used in this assessment as well (see below).

For other metals that occur naturally in soils, concentration data for the site were also screened via a comparison to background concentrations in California soils, specifically, the range between the lower 25th percentile and upper 75th percentile concentration in 50 benchmark California soil samples (Kearney Foundation of Soil Science, 1996). For arsenic, information specific to the Los Angeles basin, as noted above, is used as reported in a recent DTSC study, which calculated a 95% Upper Confidence Limit of the 99th percentile arsenic concentration of 6 mg/kg (Cal-EPA, 2005b). This value was calculated for the purpose of the comparison with the maximum concentration measured at a site.

For petroleum-related chemicals measured as total petroleum hydrocarbons (TPHs) within a specific petroleum product category (e.g., fuel oil, bunker oil, lubricating oil, etc.), neither a CHHSL nor a PRG is available for a screening-level comparison. Therefore, we use the ESL developed by the San Francisco Bay RWQCB for TPH (RWQCB, 2005). The ESL for TPH within the residual fuel category and intended for use with commercial/industrial land use is chosen for the purpose of this comparison; this value is 1,000 mg/kg. Likewise, CHHSLs are not available for volatile organic compounds (VOCs), such as benzene, ethylbenzene, toluene, and xylene, and for these chemicals, the PRGs were used as comparative benchmarks.

PREVIOUS INVESTIGATIONS In connection with Chevron’s closure activities, initial soil sampling, for the purposes of characterizing the site, was conducted on November 1, 1990 (Samples 454-1, 454-1A, 454-2, and 454-2A); November 16, 1990 (Samples 200A/B – 207A/B); and December 4, 1990 (Samples 209A/B – 211A/B). Samples described as representative were collected at a depth of 6 inches below ground surface (bgs). These soil samples were analyzed for pH,

3 The Los Angeles RWQCB has not developed ESLs.

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heavy metals, total recoverable petroleum hydrocarbons (TRPH), aromatic organics (benzene, toluene, ethylbenzene, and xylenes [BTEX]), volatile organics, semi-volatile organics, and polychlorinated biphenyls (PCBs) by EPA Methods 9045, 7040-7950, 418.1, 8020, 8010/8240, 636/8270, and 8080, respectively (Law/Crandall, 1991). Results from each of these sampling events and subsequent mitigation actions, by analyte, are as follows.

PCBs

• Four out of 18 samples analyzed (210A, 210B, 454-1, and 454-2A) had PCB (as Aroclor 1254) concentrations of 7.5, 7.4, 0.42, and 0.37 mg/kg, respectively. PCB concentrations in other samples were below limits of detection.

• Chevron excavated and removed the soil and took an additional four samples (212A – 215A) on December 27, 1990. The analysis of these samples reported no detectable PCBs (<1.0 mg/kg).

Metals

• All metals detected were below the Title 22 total threshold limit concentration (TTLC) and soluble threshold limit concentration (STLC) used to define hazardous waste in California.

• Arsenic concentrations in 14 of 15 samples exceeded the CHHSL of 0.24 mg/kg, while 11 of 15 samples exceeded the Cal-EPA background benchmark of 6 mg/kg (Cal-EPA, 2005b) (Table 1).

• Detections of all other metals were below their corresponding CHHSL values.

• The potential significance of measured levels of metals on human health was not evaluated at the time of the investigation and no metals were excavated and removed except as might occur as part of the excavation associated with PCB, TRPH, and BTEX removal.

TRPH and BTEX

• TRPH concentrations ranging from 14 to 30,000 mg/kg were detected in 12 of 18 samples. Soil with concentrations exceeding a target level of 1,000 mg/kg were removed in subsequent removal actions (see below).

• Trace levels of BTEX were detected in samples 209A/B, 210A/B, and 211A/B. The highest concentration of benzene was 0.009 mg/kg, which is well below the PRG for industrial soils of 1.4 mg/kg.

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• Concentrations of toluene, ethylbenzene, and xylenes were detected at levels well below their respective PRGs in all three sample areas.

SVOCs

• Trace levels of chrysene and pyrene were detected in one of 18 samples (207A/B) at concentrations of 0.7 mg/kg and 0.8 mg/kg, respectively. Both are well below the PRGs of 13 mg/kg and 29,000 mg/kg, respectively.

VOCs

• In 15 of 15 samples, no VOCs, other than BTEX, were detected.

Starting in December 1990, it was reported that Chevron excavated and removed soil visibly affected by oil (staining/discoloration) to an off-site permitted facility. Hexane extraction tests in the field were also performed to augment the visual identification of oil-affected soil. Soil testing positive by the hexane tests was considered to be oil-affected and excavated and transported off site. The extent of the hexane testing was not described. Soil that tested negative using the hexane test was reportedly confirmed by chemical analysis of a representative grab sample (confirmation sample).

CONFIRMATION SAMPLING RESULTS Chevron collected confirmation samples in late 1990 and 1991. Confirmation samples were analyzed for TRPH and BTEX. The target concentration for TRPH was 1,000 mg/kg. Because concentrations of BTEX were low, it was determined by Chevron that there was no need for the establishment of a BTEX-specific remediation level. Soil areas with representative samples containing TRPH concentrations below the target level were not removed. The soil areas with representative samples with concentrations exceeding the target level of 1,000 mg/kg were removed and another confirmation sample was taken at the same location. Confirmation grab samples were taken at a depth of 6 inches below the surface in the excavated areas. The depth of excavation at each sample location was not reported. Results from confirmation samples were as follows.

Bermed Area

• A total of 44 samples were taken during the course of two sampling events on December 27, 1990 (208B – 227B) and February 11, 1991 (1 – 4 and 208 – 227) (Figure 1). Samples were analyzed for TRPH and BTEX.

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• Five of the 44 samples (209B, 211B, 212, 215B, and 220) had TRPH concentrations greater than the target level of 1,000 mg/kg. The soil areas represented by these samples were excavated, removed, and resampled on January 22, 1991 and February 13, 1991. [Data representing soil that has been removed are not presented in the tables.]

• Re-confirmation samples C-209B, C-211B, 212, C-215B, and 220 for the above samples had TRPH concentrations below the target level (<1.0 mg/kg, <1.0 mg/kg, 170 mg/kg, 56 mg/kg and 17 mg/kg, respectively). (These data are considered to replace the 5 original data points noted above [209B, 211B, 212, 215B, and 220] and are presented in Table 2.)

• Six additional “final” confirmation samples (for a total of 50 samples in this area) were taken and analyzed between the dates of February 15, 1991 and October 9, 1991 (Samples 200, 201, S2-1B to S2-4B). All six samples had concentrations below the target concentration of 1,000 mg/kg for TRPH (Table 2).

• None out of a total of 50 confirmation samples collected and analyzed between the dates of December 27, 1990 and October 9, 1991 and representing soil that has not been removed had concentrations at or above the ESL of 1000 mg/kg (RWQCB, 2005) [Maximum of 670 mg/kg] (Table 2).

• Benzene was not detected in any of the 46 samples analyzed for BTEX, as shown in Table 2. (The number of samples analyzed for BTEX is 46 rather than 50 because data includes 4 re-confirmation samples that were analyzed for TRPH only, as shown in Table 2.) Toluene was detected in two of 46 samples with a maximum concentration of 0.008 mg/kg. Ethylbenzene was detected in three of 46 samples with a maximum concentration of 0.043 mg/kg. Xylene was detected in 12 of 46 samples with a maximum concentration of 0.044 mg/kg. Concentrations of toluene, ethylbenzene, and xylene were less than their respective PRGs.

Former Production Facilities Area

• On February 20, 1991, a total of 77 samples were taken and analyzed for TRPH and BTEX (Samples 200A – 276A) (Figure 1).

• TRPH was detected in five of the 77 samples (202A, 214A, 221A, 239A, and 247A) with concentrations greater than the target level. The soil areas represented by these samples were excavated, removed off site, and resampled on February 25,

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1991. [These and other data representing soil that has been removed are not presented in the tables.]

• Re-confirmation Samples 202B, 214B, 221B, 239B, and 247B had concentrations below the TRPH target concentration (340 mg/kg, 53 mg/kg, <1.0 mg/kg, 83 mg/kg, and <1.0 mg/kg). These data are considered as replacements for the five original data points mentioned above, as the soil represented by the original points was removed; only data reflecting possible current conditions are presented in Table 3.

• Four additional “final” confirmation samples (202 and S2-1F to S2-3F) [for a total of 81 samples] were collected on February 15, 1991 and October 9, 1991. All four samples resulted in TRPH concentrations below the target level of 1,000 mg/kg.

• None of the 81 samples presented in Table 3 and representing soil that has not been removed had concentrations of TRPH equal to or above the current ESL of 1,000 mg/kg (maximum of 600 mg/kg).

• Benzene was detected in one of 78 samples analyzed for BTEX at sample location 240A (0.009 mg/kg). (The number of samples is 78 rather than 81 because the data includes three re-confirmation samples, which were analyzed only for TRPH, as shown in Table 3.) Toluene was detected in 18 of 78 samples with a maximum concentration of 0.046 mg/kg. Ethylbenzene was detected in nine of 78 samples with a maximum concentration of 0.041 mg/kg. Xylene was detected in 41 of 78 samples with a maximum concentration of 0.2 mg/kg. Concentrations of BTEX were less than their respective PRGs.

Former Well Vault Area

• A total of 57 samples were taken during the course of two confirmation sampling events on February 1, 1991 (228B – 266B, no Sample 262B) and February 7, 1991 (267B – 288B) (Figure 1). Samples were analyzed for TRPH and BTEX.

• Twelve of the 57 samples had TRPH concentrations greater than the target level. The soil represented by these samples was subsequently excavated, removed off site, and resampled on February 13, 1991 and April 25, 1991. [The data representing soil that has been removed are not presented in this report.]

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• The 12 re-confirmation samples had TRPH concentrations below the target level. (These data are considered to replace the original data points mentioned above and therefore, these newer data only are included in Table 4).

• Eight additional “final” confirmation samples were collected on February 15, 1991 (203, 204, and 205), February 22, 1991 (S2-1WW, S2-10W, and S2-20W), and on October 9, 1991 (S2-30W and S2-40W) [for a total of 65 samples]. TRPH concentrations were well below the target level.

• None of the 65 confirmation samples had concentrations equal to or above the current ESL of 1000 mg/kg for TRPH (maximum of 810 mg/kg) (Table 4).

• Benzene and toluene were not detected in any of the 60 samples analyzed for BTEX. BTEX was not sampled for in five of the 65 samples (S2-1WW, S2-10W, S2-20W, S2-30W, and S2-40W). Ethylbenzene was detected in 1 of 60 samples with a concentration of 0.006 mg/kg. Xylene was detected in nine of 60 samples with a maximum concentration of 0.017 mg/kg. Concentrations of ethylbenzene and xylene were less than their respective PRGs.

CURRENT SITE CONDITIONS Review of the previous investigations and mitigation activities support that soils on site currently may have concentrations of TRPH that range from non-detect to a maximum of 810 mg/kg (in the former well vault area). All values are less than 1000 mg/kg (as residual fuels) and are therefore below the applicable ESL. This ESL is appropriate for a construction worker scenario4.

Residual trace levels of toluene, ethylbenzene, and xylene, as detected in a few samples, are all well below PRGs for commercial/industrial soils5. With the exception of one location, benzene was not detected in soil. A trace quantity of benzene (0.009 mg/kg) was detected in confirmation Sample 240A located in the Former Production Facilities Area (see Figure 1). This concentration is substantially below the applicable benzene PRG of 1.4 mg/kg6.

4 The majority of samples and any measure of the mean concentration of TRPH currently present in site soils would also be below the ESL for residential soils (500 mg/kg). 5 Measured levels would be well below the residential screening levels as well, which are 520, 400, and 270 mg/kg for toluene, ethylbenzene, and xylenes, respectively. 6 This detected benzene concentration is also below the PRG for residential soils, which is 0.64 mg/kg.

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Trace concentrations of SVOCs and PCBs were detected in the preliminary site characterization investigation in soils that were subsequently removed. No PCBs were detected in confirmation sampling conducted after soil removal (Law/Crandall, 1991). It is noted in the Law/Crandall (1991) investigation that excavation across the site ranged from a depth of 2 to 16 feet below the original surface. The report further states that trace levels of PCB (as Aroclor 1254) (Samples 454-1 and 454-2A) and SVOCs were most likely removed off-site during the excavation and removal activities.

Metals were analyzed in the preliminary site characterization investigation. A total of seventeen metals were compared to TTLC and STLC concentrations for the purpose of certifying site soils as non-hazardous under the California Code of Regulations, Title 22 requirements. As reported, none of the metals exceeded TTLC or STLC concentration limits and the soil impacted by historical site activities was excavated and transported off site as non-hazardous waste. Metals were not detected above CHHSL levels with the exception of arsenic. Comparing sample results to the Los Angeles basin background levels developed by the DTSC (Cal-EPA, 2005b) showed 11 samples with levels of arsenic in excess of 6 mg/kg. The maximum detected concentration (18 mg/kg), however, was only slightly above the normal range of background concentrations found in Los Angeles county soils.

CONCLUSION It is our understanding that as the site is developed, additional excavation will be required. The entire site will be excavated to 50 feet bgs measured from street level. Since prior excavations have left the site surface at between 10 and 30 feet bgs, an additional 20 to 40 feet of soil removal will be required. Further, we understand that the site will be a high rise residential structure with four levels of underground parking and with residential units above the parking and common areas. This information is of value in determining the significance of the soil analytical results.

TRPH concentrations in all of the 196 sample locations were found to be less than the ESL of 1000 mg/kg, which is applicable to construction worker exposures (commercial/industrial soils)7. ESLs assume direct contact with soil and/or potential exposure to chemical vapors released from soil into the indoor space of residential dwelling.

7 The majority of TRPH concentrations, and likely any measure of the average, site-wide TRPH concentration, would also be below the residential ESL of 500 mg/kg also.

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The proposed site development does not offer the potential for direct soil contact for site residences and the infrastructure that will be built between the soil surface and the residential units would greatly attenuate, if not completely eliminate, potential exposure to soil vapors. Additionally, the property is in the City’s methane zone, so it is expected to have a methane mitigation system that includes soil gas collection and venting and a vapor barrier. This type of system would provide an additional control feature, minimizing site exposures to volatile chemicals in the soil, if any. Finally, an additional 20 to 40 feet of soil will be removed from the site. Based on the history of chemical detections at the site, this soil removal would be expected to also remove residual TRPH. Therefore, we believe that the use of screening criteria (e.g., CHHSLs, PRGs, and ESLs) for commercial/industrial soils is protective of construction workers and future residents at the site8.

Also of interest in interpreting the significance of these results, laboratory data sheets indicate that EPA Method 418.1 was used for TRPH soil analysis. EPA Method 418.1 is an infrared measurement of carbon-hydrogen bonds that is not specific to petroleum hydrocarbons. Measurement of compounds with carbon-hydrogen bonds other than petroleum hydrocarbons can artificially increase the reported concentration. In addition, the responsiveness of the measurement varies depending on the complex mixture of petroleum hydrocarbons in the sample. Therefore, measured TRPH concentrations may not represent accurate measurements of petroleum hydrocarbons and may exaggerate detected levels. Nevertheless, even if biased high, measured levels of TRPH are below the ESL and do not represent an unacceptable risk to on-site workers.

Excavation of soils targeting PCBs, BTEX, and TRPH contamination across the site removed soil at depths ranging from 2 to 16 feet below the original surface. Because the initial samples for metals were taken at 6 inches bgs, it is likely that those locations where metals (arsenic) exceeded background concentrations, if any, (and by default the CHHSLs) were removed during the remedial activities. However, confirmation samples were not collected, so this was not verified. In these cases, the Office of Environmental Health Hazard Assessment (OEHHA) recommends a Tier 2 evaluation, which utilizes a modified CHHSL. CHHSLs are to be modified based on site-specific characteristics, which are more consistent with the exposure receptors and pathways anticipated for the site. While we have applied a CHHSL (0.24 mg/kg), which is already applicable to occupational (non-residential) exposure scenarios, for settings involving construction workers only, the default exposure duration of 25 years might be substituted with a more likely value of 1 year. Further, the CHHSL for arsenic was derived based on protection at a one-in-one-million 8 Also, as noted elsewhere, the average, site-wide TRPH concentrations, which remain in site soils following the substantial remedial activities focusing on the most concentrated areas over the past 15 years, are expected to be substantially below the residential ESL of 500 mg/kg as well.

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(10-6) cancer risk level. Cancer risk levels in the range of 10-5 (10 in one million) to 10-3 (1,000 in one million) are more typically applied to the regulation of worker risks, partly based on the voluntary nature of the risks incurred by workers and the relatively small number of workers in actual contact with site-related contaminants. Therefore, the OEHHA modified CHHSL accounts for a target risk of 10-5. These two modifications to the CHHSLs translate to adjustment factors of 250, and thus, a modified CHHSL of 60 mg/kg (0.24 mg/kg × 250 adjustment factor) would still be considered protective of construction workers at the site. The highest concentration of arsenic (18 mg/kg) at the site is well below a CHHSL that is modified based on the exposure expected for a construction worker scenario.

It might also be considered that standard safety precautions, as expected to be incorporated into health and safety plans for construction at sites like this, evaluate and control worker exposures to soils to avoid unnecessary health impacts. Safety procedures taken to protect worker health at the excavation of this site should likely include worker training, personal protective equipment as appropriate, monitoring of exposures, and the establishment of procedures for reacting to the discovery of unexpected materials during excavation.

Given the long-term historic use of the site for oil and gas production, it is possible that some subsurface conditions may not have been identified during previous investigations. As a precaution, and to minimize disruption to construction/development activities, a site management plan is typically developed that informs contractors regarding site history and provides guidelines for addressing visibly affected soil (e.g., staining/odors) identified during construction. We recommend that this potential be considered and the appropriate controls developed as the project moves forward.

For future residents at the site, the lack of direct contact with site soil eliminates any concern over the presence of arsenic, if indeed arsenic levels are elevated over background after removal of additional soils.

To develop these conclusions, Geomatrix relied on the accuracy of information in the Law/Crandall report as provided and did not conduct an independent investigation at the site. No other information for the site was provided or considered in developing this evaluation. Geomatrix assumes no responsibility for any consequence arising from any information or condition that was concealed, withheld, misrepresented, or otherwise not fully disclosed or available to Geomatrix.

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We are available at your convenience, if you have any comments or questions.

Sincerely yours, GEOMATRIX CONSULTANTS, INC.

Kevin Connor, Ph.D. James W. Embree, Ph.D., DABT Senior Toxicologist Principal Toxicologist \projects\10181 urban development\century city realty

Attachments: References Tables Figure

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REFERENCES Bosan, W.S., G. Chernoff, J. Christopher, M. Rawat and D. Oudiz. Evaluation of Arsenic as a

Chemical of Potential Concern at Proposed School Sites in the Los Angeles Area. Human and Ecological Risk Division, Department of Toxic Substances Control, Sacramento, CA. Undated. (Accessible via www.dtsc.ca.gov as of February 2, 2006).

Cal-EPA, 2005a, Use of California Human Health Screening Levels (CHHSLs) in Evaluation of Contaminated Properties. Office of Environmental Health Hazard Assessment. California Environmental Protection Agency, Sacramento, CA. January. Accessed at: http://www.calepa.ca.gov/Brownfields/SB32.htm.

Cal-EPA, 2005b, Final Report—Background Metals at Los Angeles Unified Schools Sites – Arsenic. Department of Toxic Substances Control, California Environmental Protection Agency, Sacramento, CA. June, 6.

Kearney Foundation of Soil Science, 1996, Background Concentrations of Trace and Major Elements in California Soils, Division of Agriculture and Natural Resources, University of California, March.

Law/Crandall, Inc., 1991. Closure Report for the Chevron Drill Site 2 for the JMB/Urban Development Company.

Regional Water Quality Control Board (RWQCB), San Francisco Bay Region, 2005 Screening for Environmental Concerns at Site with Contaminated Soil and Groundwater, Volume 2, Interim Final, February.

U.S. EPA, 2004, Preliminary Remediation Goals (PRGs): U.S. Environmental Protection Agency, Region IX, October 2004.

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TABLE 1INITIAL SITE SURVEY RESULTS

METALSUrban Development Services

10131 Constellation Blvd., Century City, California

Concentrations in miligrams per kilogram (mg/kg)Sample

LocationSample

DateDepth(ft bgs) Antimony Arsenic Barium Beryllium Cadmium Chromium1 Cobalt Copper Lead Mercury Molybdenum Nickel Selenium Silver Thallium Vanadium Zinc

200A/B 11/16/1990 0.5 -8 11 99 0.68 0.3 31 7.1 22 5.9 -0.17 -0.4 19 -1 -0.4 -3 59 52201A/B 11/16/1990 0.5 -8 7.8 120 0.66 0.5 32 8 23 13 -0.17 0.7 18 -1 -0.4 -3 59 55202A/B 11/16/1990 0.5 -8 5.8 160 0.48 1.7 25 6.5 23 38 0.24 0.5 15 -1 -0.4 -3 45 78203A/B 11/16/1990 0.5 -8 5.2 310 0.28 1.2 46 13 120 93 2.9 2.9 120 -1 -0.4 -3 48 120204A/B 11/16/1990 0.5 -8 11 94 0.67 0.4 33 6.1 22 8.5 -0.17 -0.4 16 -1 -0.4 -3 62 48205A/B 11/16/1990 0.5 -8 9.1 230 0.64 0.8 27 7.5 25 16 0.74 1.1 21 -1 -0.4 -3 58 60206A/B 11/16/1990 0.5 -8 5.5 430 0.49 1 38 7.1 38 31 0.58 0.3 15 -1 -0.4 -3 55 92207A/B 11/16/1990 0.5 -8 -1 330 0.34 0.5 12 6.4 14 21 0.23 -0.4 6.4 -1 -0.4 -3 41 59209A 12/4/1990 0.5 -2 11 160 -0.5 -0.5 18 9.1 20 20 -0.02 -2 12 -0.05 -0.5 -2 29 69210A 12/4/1990 0.5 -2 10 380 -0.5 -0.5 42 8.2 60 49 1.4 -2 17 -0.05 -0.5 -2 73 190211A 12/4/1990 0.5 -2 18 84 -0.5 -0.5 31 8.4 22 3.4 -0.02 -2 20 -0.05 -0.5 -2 8.4 5.4454-1 11/1/1990 0.5 -8 14 760 0.76 1.2 44 9.8 200 45 -0.17 0.5 25 -1 1.3 -2 71 410

454-1A 11/1/1990 0.5 -8 14 470 0.77 1.1 39 9.7 130 34 -0.17 0.6 24 -1 0.9 -2 69 320454-2 11/1/1990 0.5 -8 11 280 0.84 1 37 9.8 56 21 0.26 0.3 23 -1 -0.8 -2 72 1300

454-2A 11/1/1990 0.5 -8 13 340 0.77 1.5 35 10 73 28 -0.17 0.4 25 -1 0.9 -2 69 1900Count (n) 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15

Number of Detects 0 14 15 12 12 15 15 15 15 7 9 15 0 3 0 15 15Number of Non-Detects 15 1 0 3 3 0 0 0 0 8 6 0 15 12 15 0 0

Minimum Detection 0 5.2 84 0.28 0.3 12 6.1 14 3.4 0.23 0.3 6.4 0 0.9 0 8.4 5.4Maximum Detection 0 18 760 0.84 1.7 46 13 200 93 2.9 2.9 120 0 1.3 0 73 1900

Minimum Detection Limit 2 1 0 0.5 0.5 0 0 0 0 0.02 0.4 0 0.05 0.4 2 0 0Maximum Detection Limit 8 1 0 0.5 0.5 0 0 0 0 0.17 2 0 1 0.8 3 0 0

Detection Frequency 0% 93% 100% 80% 80% 100% 100% 100% 100% 47% 60% 100% 0% 20% 0% 100% 100%

Default Screening Level (Industrial Soils) 380 0.24 63,000 1,700 7.5 10,000 (Cr-III) 3,200 38,000 3,500 180 4,800 16,000 4,800 4,800 63 6,700 10,000Tier 2 Screening Level (Constr. Worker)2 -- 60 -- -- -- -- -- -- -- -- -- -- -- -- -- -- --

Rationale 3 CHHSL CHHSL CHHSL CHHSL CHHSL CHHSL CHHSL CHHSL CHHSL CHHSL CHHSL CHHSL CHHSL CHHSL CHHSL CHHSL CHHSL

Background 4, 5 (lower 25th percentile) 0.33 N/A 375 0.92 0.15 45 8.7 16.1 16 0.1 0.6 21 0.015 0.22 9.8 75 133(upper 75th percentile)5 0.73 6 (5) 625 1.53 0.44 115 18.3 36.6 26.7 0.34 1.4 56 0.05 0.53 0.69 134 170

Chemical of Potential Concern?6 NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO

Notes:1 Chromium assumed to be predominantly trivalent species; fraction that is hexavalent species would likely be well below corresponding PRG (for Cr-VI) of 37 mg/mg as well. 2 Screening criterion is adjusted for 1 year exposure duration of construction worker and 10-5 target risk level (see text). 3 Rationale for default soil screening levels.4 Background Concentrations of Trace and Major Elements in California Soils - Range between the Lower 25th Percentile and Upper 75th Percentile concentration (Kearney Foundation of Soil Science, 1996).5 Background comparison for arsenic uses the value from Cal-EPA (2005), which represents a 95%UCL on the 99th percentile value for soils collected from school sites within the LAUSD. 6 Chemical of potential concern if detected in more than 5 percent of samples and exceeded applicable screening level and background.

Bold values denote concentrations above the detection limit.

Abbreviations:CHHSL = California Human Health Screening Level (Cal-EPA, 2005)N/A = Not applicableND = Not detected above the analyzed detection limitsft bgs = feet below ground surface

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Page 16: Century City Realty L

TABLE 2HYDROCARBON ANALYSIS RESULTS OF CONFIRMATION SOIL SAMPLES

BERMED AREAUrban Development Services

10131 Constellation Blvd., Century City, California

Concentrations in miligrams per kilogram (mg/kg)

Sample ID DateDepth(ft bgs) TRPH Benzene Toluene

Ethyl-benzene Xylenes

1 2/11/1991 0.5 120 -0.005 -0.005 -0.005 0.0072 2/11/1991 0.5 -1 -0.005 -0.005 -0.005 -0.0053 2/11/1991 0.5 400 -0.005 0.006 -0.005 0.0084 2/11/1991 0.5 8 -0.005 -0.005 -0.005 -0.005

200 2/15/1991 1.5 -1 -0.005 -0.005 -0.005 -0.005201 2/15/1991 1.5 -1 -0.005 -0.005 -0.005 -0.005208 2/11/1991 0.5 340 -0.005 -0.005 -0.005 0.008209 2/11/1991 0.5 33 -0.005 -0.005 -0.005 -0.005210 2/11/1991 0.5 4 -0.005 -0.005 -0.005 -0.005211 2/11/1991 0.5 57 -0.005 0.008 0.043 0.044212 2/13/1991 0.5 170 -0.005 -0.005 -0.005 -0.005213 2/11/1991 0.5 210 -0.005 -0.005 -0.005 0.007214 2/11/1991 0.5 17 -0.005 -0.005 -0.005 -0.005215 2/11/1991 0.5 -1 -0.005 -0.005 -0.005 -0.005216 2/11/1991 0.5 500 -0.005 -0.005 -0.005 0.011217 2/11/1991 0.5 67 -0.005 -0.005 -0.005 -0.005218 2/11/1991 0.5 16 -0.005 -0.005 -0.005 -0.005219 2/11/1991 0.5 -1 -0.005 -0.005 -0.005 -0.005220 2/13/1991 0.5 17 -0.005 -0.005 -0.005 -0.005221 2/11/1991 0.5 42 -0.005 -0.005 -0.005 0.01222 2/11/1991 0.5 -1 -0.005 -0.005 -0.005 0.007223 2/11/1991 0.5 -1 -0.005 -0.005 -0.005 -0.005224 2/11/1991 0.5 8.4 -0.005 -0.005 -0.005 -0.005225 2/11/1991 0.5 8.4 -0.005 -0.005 -0.005 -0.005226 2/11/1991 0.5 27 -0.005 -0.005 -0.005 0.008227 2/11/1991 0.5 -1 -0.005 -0.005 -0.005 -0.005

208B 12/27/1990 0.5 -1 -0.005 -0.005 -0.005 -0.005210B 12/27/1990 0.5 420 -0.005 -0.005 0.035 0.033212B 12/27/1990 0.5 290 -0.005 -0.005 -0.005 -0.005213B 12/27/1990 0.5 110 -0.005 -0.005 -0.005 -0.005214B 12/27/1990 0.5 340 -0.005 -0.005 -0.005 -0.005216B 12/27/1990 0.5 550 -0.005 -0.005 -0.005 -0.005217B 12/27/1990 0.5 670 -0.005 -0.005 -0.005 -0.005218B 12/27/1990 0.5 73 -0.005 -0.005 -0.005 -0.005219B 12/27/1990 0.5 410 -0.005 -0.005 -0.005 0.014220B 12/27/1990 0.5 27 -0.005 -0.005 -0.005 -0.005221B 12/27/1990 0.5 183 -0.005 -0.005 -0.005 -0.005222B 12/27/1990 0.5 18 -0.005 -0.005 -0.005 -0.005223B 12/27/1990 0.5 150 -0.005 -0.005 -0.005 -0.005224B 12/27/1990 0.5 220 -0.005 -0.005 0.01 0.021225B 12/27/1990 0.5 36 -0.005 -0.005 -0.005 -0.005226B 12/27/1990 0.5 200 -0.005 -0.005 -0.005 -0.005227B 12/27/1990 0.5 46 -0.005 -0.005 -0.005 -0.005

C-209B 1/22/1991 0.5 -1 -0.005 -0.005 -0.005 -0.005

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Page 17: Century City Realty L

TABLE 2HYDROCARBON ANALYSIS RESULTS OF CONFIRMATION SOIL SAMPLES

BERMED AREAUrban Development Services

10131 Constellation Blvd., Century City, California

Concentrations in miligrams per kilogram (mg/kg)

Sample ID DateDepth(ft bgs) TRPH Benzene Toluene

Ethyl-benzene Xylenes

C-211B 1/22/1991 0.5 -1 -0.005 -0.005 -0.005 -0.005C-215B 1/22/1991 0.5 56 -0.005 -0.005 -0.005 -0.005S2-1B 2/22/1991 1.0 -10 NA NA NA NAS2-2B 2/22/1991 1.0 -10 NA NA NA NAS2-3B 10/9/1991 1.0 24 NA NA NA NAS2-4B 10/9/1991 1.0 26 NA NA NA NA

Count (n) 50 46 46 46 46Number of Detects 37 0 2 3 12

Number of Non-Detects 13 46 44 43 34Minimum Detection 4 0 0.006 0.01 0.007Maximum Detection 670 0 0.008 0.043 0.044

Minimum Detection Limit 1 0.005 0.005 0.005 0.005Maximum Detection Limit 10 0.005 0.005 0.005 0.005

Detection Frequency 74% 0% 4% 7% 26%Construction Worker Screening Level 1000 1.4 520 400 420

Rationale1 ESL(DE) PRG(DE) PRG(DE) PRG(DE) PRG(DE)Chemical of Potential Concern?2 NO NO NO NO NO

Notes:1 Rationale for residential and construction worker screening levels:

PRG = Region 9 U.S. EPA Preliminary Remediation Goal.(DE) = Screening Level based on direct exposure.

Abbreviations:-0.005 = Sample result below the detection limit indicatedNA = Not AnalyzedTRPH = Total Recoverable Petroleum Hydrocarbons

2 Chemical of potential concern if detected in more than 5 percent of samples and exceeded screening level.

ESL = values from California Regional Water Quality Control Board, San Francisco Bay Region, 2005, Screening for Environmental Concerns at Sites with Contaminated Soil and Groundwater, Interim Final, February. Direct-Exposure Screening Levels, Table K-2 for commercial/industrial worker exposure scenario.

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Page 18: Century City Realty L

TABLE 3HYDROCARBON ANALYSIS RESULTS OF CONFIRMATION SOIL SAMPLES

FORMER PRODUCTION FACILITIES AREAUrban Development Services

10131 Constellation Blvd., Century City, California

Concentrations in miligrams per kilogram (mg/kg)

Sample ID DateDepth(ft bgs) TRPH Benzene Toluene

Ethyl-benzene Xylenes

200A 2/20/1991 0.5 110 -0.005 -0.005 -0.005 -0.005201A 2/20/1991 0.5 250 -0.005 -0.005 -0.005 -0.005202 2/15/1991 1.5 -1 -0.005 -0.005 -0.005 -0.005

202B 2/25/1991 0.5 340 -0.005 -0.005 -0.005 -0.005203A 2/20/1991 0.5 100 -0.005 -0.005 -0.005 -0.005204A 2/20/1991 0.5 270 -0.005 -0.005 -0.005 -0.005205A 2/20/1991 0.5 18 -0.005 -0.005 -0.005 -0.005206A 2/20/1991 0.5 68 -0.005 -0.005 -0.005 -0.005207A 2/20/1991 0.5 230 -0.005 -0.005 -0.005 -0.005208A 2/20/1991 0.5 430 -0.005 -0.005 -0.005 0.006209A 2/20/1991 0.5 160 -0.005 -0.005 -0.005 -0.005210A 2/20/1991 0.5 82 -0.005 -0.005 -0.005 -0.005211A 2/20/1991 0.5 18 -0.005 -0.005 -0.005 -0.005212A 2/20/1991 0.5 150 -0.005 -0.005 -0.005 -0.005213A 2/20/1991 0.5 290 -0.005 -0.005 -0.005 -0.005214B 2/25/1991 0.5 53 -0.005 -0.005 -0.005 -0.005215A 2/20/1991 0.5 26 -0.005 -0.005 -0.005 0.009216A 2/20/1991 0.5 -1 -0.005 -0.005 -0.005 0.015217A 2/20/1991 0.5 230 -0.005 -0.005 -0.005 0.01218A 2/20/1991 0.5 340 -0.005 -0.005 -0.005 -0.005219A 2/20/1991 0.5 -1 -0.005 -0.005 -0.005 0.011220A 2/20/1991 0.5 49 -0.005 -0.005 -0.005 0.017221B 2/25/1991 0.5 -1 -0.005 -0.005 -0.005 -0.005222A 2/20/1991 0.5 46 -0.005 -0.005 -0.005 -0.005223B 2/25/1991 0.5 25 -0.005 -0.005 0.009 -0.005224A 2/20/1991 0.5 440 -0.005 -0.005 -0.005 0.011225A 2/20/1991 0.5 91 -0.005 -0.005 -0.005 -0.005226A 2/20/1991 0.5 62 -0.005 -0.005 -0.005 0.016227A 2/20/1991 0.5 300 -0.005 -0.005 -0.005 0.009228A 2/20/1991 0.5 120 -0.005 -0.005 -0.005 -0.005229A 2/20/1991 0.5 160 -0.005 -0.005 -0.005 -0.005230A 2/20/1991 0.5 64 -0.005 -0.005 -0.005 -0.005231A 2/20/1991 0.5 -1 -0.005 -0.005 -0.005 -0.005232A 2/20/1991 0.5 -1 -0.005 -0.005 -0.005 -0.005233A 2/20/1991 0.5 230 -0.005 0.006 -0.005 0.009234A 2/20/1991 0.5 570 -0.005 -0.005 -0.005 0.013235A 2/20/1991 0.5 -1 -0.005 -0.005 -0.005 0.006236A 2/20/1991 0.5 220 -0.005 0.007 0.005 0.032237A 2/20/1991 0.5 100 -0.005 -0.005 -0.005 0.006238A 2/20/1991 0.5 44 -0.005 0.039 0.041 0.2239B 2/25/1991 0.5 83 -0.005 -0.005 -0.005 -0.005240A 2/20/1991 0.5 330 0.009 0.046 0.016 0.073241A 2/20/1991 0.5 36 -0.005 -0.005 -0.005 -0.005242A 2/20/1991 0.5 250 -0.005 0.006 -0.005 0.019243A 2/20/1991 0.5 600 -0.005 0.013 0.007 0.034244A 2/20/1991 0.5 560 -0.005 -0.005 -0.005 0.011245A 2/20/1991 0.5 410 -0.005 -0.005 -0.005 0.009246A 2/20/1991 0.5 290 -0.005 -0.005 -0.005 0.017247B 2/25/1991 0.5 -1 -0.005 -0.005 -0.005 -0.005248A 2/20/1991 0.5 130 -0.005 0.01 -0.005 0.023249A 2/20/1991 0.5 150 -0.005 -0.005 -0.005 0.015250A 2/20/1991 0.5 120 -0.005 0.005 -0.005 0.013251A 2/20/1991 0.5 180 -0.005 -0.005 -0.005 0.014

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Page 19: Century City Realty L

TABLE 3HYDROCARBON ANALYSIS RESULTS OF CONFIRMATION SOIL SAMPLES

FORMER PRODUCTION FACILITIES AREAUrban Development Services

10131 Constellation Blvd., Century City, California

Concentrations in miligrams per kilogram (mg/kg)

Sample ID DateDepth(ft bgs) TRPH Benzene Toluene

Ethyl-benzene Xylenes

252A 2/20/1991 0.5 50 -0.005 -0.005 -0.005 -0.005253A 2/20/1991 0.5 130 -0.005 -0.005 -0.005 -0.005254A 2/20/1991 0.5 480 -0.005 0.005 -0.005 0.028255A 2/20/1991 0.5 65 -0.005 -0.005 -0.005 0.006256A 2/20/1991 0.5 280 -0.005 -0.005 -0.005 -0.005257A 2/20/1991 0.5 550 -0.005 -0.005 -0.005 0.007258A 2/20/1991 0.5 220 -0.005 -0.005 -0.005 0.01259A 2/20/1991 0.5 160 -0.005 -0.005 -0.005 -0.005260A 2/20/1991 0.5 90 -0.005 -0.005 -0.005 -0.005261A 2/20/1991 0.5 71 -0.005 -0.005 -0.005 -0.005262A 2/20/1991 0.5 15 -0.005 -0.005 -0.005 0.009263A 2/20/1991 0.5 50 -0.005 -0.005 -0.005 -0.005264A 2/20/1991 0.5 200 -0.005 0.016 0.006 0.024265A 2/20/1991 0.5 160 -0.005 0.01 -0.005 0.019266B 2/25/1991 0.5 55 -0.005 -0.005 -0.005 -0.005267A 2/20/1991 0.5 96 -0.005 -0.005 -0.005 -0.005268A 2/20/1991 0.5 82 -0.005 0.015 0.006 0.026269A 2/20/1991 0.5 110 -0.005 0.005 -0.005 0.018270A 2/20/1991 0.5 24 -0.005 -0.005 -0.005 0.012271A 2/20/1991 0.5 59 -0.005 0.008 -0.005 0.025272A 2/20/1991 0.5 380 -0.005 0.025 0.011 0.054273A 2/20/1991 0.5 490 -0.005 0.027 0.01 0.051274A 2/20/1991 0.5 270 -0.005 0.007 -0.005 0.012275A 2/20/1991 0.5 -1 -0.005 0.01 -0.005 0.015276A 2/20/1991 0.5 9.1 -0.005 -0.005 -0.005 0.009S2-1F 10/9/1991 1.0 29 NA NA NA NAS2-2F 10/9/1991 1.0 49 NA NA NA NAS2-3F 10/9/1991 1.0 23 NA NA NA NA

Count (n) 81 78 78 78 78Number of Detects 72 1 18 9 41

Number of Non-Detects 9 77 60 69 37Minimum Detection 9.1 0.009 0.005 0.005 0.006Maximum Detection 600 0.009 0.046 0.041 0.2

Minimum Detection Limit 1 0.005 0.005 0.005 0.005Maximum Detection Limit 1 0.005 0.005 0.005 0.005

Detection Frequency 89% 1% 23% 12% 53%Construction Worker Screening Level 1000 1.4 520 400 420

Rationale 1 ESL(DE) PRG(DE) PRG(DE) PRG(DE) PRG(DE)Chemical of Potential Concern?2 NO NO NO NO NO

Notes:1 Rationale for residential and construction worker screening levels:

PRG = Region 9 U.S. EPA Preliminary Remediation Goal.(DE) = Screening Level based on direct exposure.

Abbreviations:-0.005 = Sample result below the detection limit indicatedNA = Not AnalyzedTRPH = Total Recoverable Petroleum Hydrocarbons

2 Chemical of potential concern if detected in more than 5 percent of samples and exceeded screening level.

ESL = values from California Regional Water Quality Control Board, San Francisco Bay Region, 2005, Screening for Environmental Concerns at Sites with Contaminated Soil and Groundwater, Interim Final, February. Direct-Exposure Screening Levels, Table K-2 for commercial/industrial worker exposure scenario.

C:\Work\PROJECTS\10181 Urban Development\Table 1 (Data Tables_FEB2006) Page 5 of 7

Page 20: Century City Realty L

TABLE 4HYDROCARBON ANALYSIS RESULTS OF CONFIRMATION SOIL SAMPLES

FORMER WELL VAULT AREAUrban Development Services

10131 Constellation Blvd., Century City, California

Concentrations in miligrams per kilogram (mg/kg)

Sample ID DateDepth(ft bgs) TRPH Benzene Toluene

Ethyl-benzene Xylenes

203 2/15/1991 1.5 -1 -0.005 -0.005 -0.005 -0.005204 2/15/1991 1.5 -1 -0.005 -0.005 -0.005 -0.005205 2/15/1991 1.5 -1 -0.005 -0.005 -0.005 -0.005

228B 02/01/91 0.5 180 -0.005 -0.005 -0.005 -0.005229 02/13/91 0.5 17 -0.005 -0.005 -0.005 -0.005230 02/13/91 0.5 160 -0.005 -0.005 0.006 0.017231 04/25/91 0.5 390 -0.005 -0.005 -0.005 -0.005

232B 02/01/91 0.5 53 -0.005 -0.005 -0.005 -0.005233B 02/01/91 0.5 130 -0.005 -0.005 -0.005 -0.005234B 02/01/91 0.5 220 -0.005 -0.005 -0.005 -0.005235B 02/01/91 0.5 200 -0.005 -0.005 -0.005 -0.005236 02/13/91 0.5 120 -0.005 -0.005 -0.005 -0.005

237B 02/01/91 0.5 130 -0.005 -0.005 -0.005 -0.005238B 02/01/91 0.5 310 -0.005 -0.005 -0.005 -0.005239B 02/01/91 0.5 73 -0.005 -0.005 -0.005 -0.005240B 02/01/91 0.5 130 -0.005 -0.005 -0.005 -0.005241B 02/01/91 0.5 36 -0.005 -0.005 -0.005 -0.005242B 02/01/91 0.5 46 -0.005 -0.005 -0.005 -0.005243 02/13/91 0.5 18 -0.005 -0.005 -0.005 -0.005

244B 02/01/91 0.5 45 -0.005 -0.005 -0.005 -0.005245B 02/01/91 0.5 72 -0.005 -0.005 -0.005 -0.005246B 02/01/91 0.5 18 -0.005 -0.005 -0.005 -0.005247B 02/01/91 0.5 780 -0.005 -0.005 -0.005 -0.005248B 02/01/91 0.5 73 -0.005 -0.005 -0.005 -0.005249B 02/01/91 0.5 54 -0.005 -0.005 -0.005 -0.005250B 02/01/91 0.5 27 -0.005 -0.005 -0.005 -0.005251B 02/01/91 0.5 -1 -0.005 -0.005 -0.005 -0.005252B 02/01/91 0.5 180 -0.005 -0.005 -0.005 -0.005253B 02/01/91 0.5 200 -0.005 -0.005 -0.005 -0.005254B 02/01/91 0.5 470 -0.005 -0.005 -0.005 -0.005255B 02/01/91 0.5 160 -0.005 -0.005 -0.005 -0.005256B 02/01/91 0.5 37 -0.005 -0.005 -0.005 -0.005257B 02/01/91 0.5 -1 -0.005 -0.005 -0.005 -0.005258B 02/01/91 0.5 230 -0.005 -0.005 -0.005 -0.005259 02/13/91 0.5 -1 -0.005 -0.005 -0.005 -0.005

260B 02/01/91 0.5 37 -0.005 -0.005 -0.005 -0.005261 02/13/91 0.5 350 -0.005 -0.005 -0.005 -0.005

263B 02/01/91 0.5 150 -0.005 -0.005 -0.005 -0.005264 02/13/91 0.5 570 -0.005 -0.005 -0.005 -0.005

265B 02/01/91 0.5 400 -0.005 -0.005 -0.005 -0.005266B 02/01/91 0.5 17 -0.005 -0.005 -0.005 -0.005267B 02/07/91 0.5 210 -0.005 -0.005 -0.005 -0.005268B 02/07/91 0.5 7.2 -0.005 -0.005 -0.005 -0.005269B 02/07/91 0.5 6.3 -0.005 -0.005 -0.005 -0.005270B 02/07/91 0.5 3.5 -0.005 -0.005 -0.005 -0.005271B 02/07/91 0.5 19 -0.005 -0.005 -0.005 0.005272B 02/07/91 0.5 130 -0.005 -0.005 -0.005 -0.005273 02/13/91 0.5 37 -0.005 -0.005 -0.005 -0.005

274B 02/07/91 0.5 220 -0.005 -0.005 -0.005 -0.005275B 02/07/91 0.5 780 -0.005 -0.005 -0.005 -0.005276B 02/07/91 0.5 670 -0.005 -0.005 -0.005 -0.005277B 02/07/91 0.5 6.4 -0.005 -0.005 -0.005 -0.005278B 02/07/91 0.5 640 -0.005 -0.005 -0.005 0.008

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Page 21: Century City Realty L

TABLE 4HYDROCARBON ANALYSIS RESULTS OF CONFIRMATION SOIL SAMPLES

FORMER WELL VAULT AREAUrban Development Services

10131 Constellation Blvd., Century City, California

Concentrations in miligrams per kilogram (mg/kg)

Sample ID DateDepth(ft bgs) TRPH Benzene Toluene

Ethyl-benzene Xylenes

279 02/13/91 0.5 92 -0.005 -0.005 -0.005 -0.005280B 02/07/91 0.5 810 -0.005 -0.005 -0.005 0.011281B 02/07/91 0.5 240 -0.005 -0.005 -0.005 0.006282 04/25/91 0.5 260 -0.005 -0.005 -0.005 -0.005

283B 02/07/91 0.5 250 -0.005 -0.005 -0.005 0.005284B 02/07/91 0.5 44 -0.005 -0.005 -0.005 0.005285B 02/07/91 0.5 670 -0.005 -0.005 -0.005 0.007286B 02/07/91 0.5 230 -0.005 -0.005 -0.005 0.006287 02/13/91 0.5 46 -0.005 -0.005 -0.005 -0.005

288B 02/07/91 0.5 260 -0.005 -0.005 -0.005 -0.005S2-1WW 02/22/91 1.0 -10 NA NA NA NAS2-10W 02/22/91 1.0 -10 NA NA NA NAS2-20W 02/22/91 1.0 -10 NA NA NA NAS2-30W 10/09/91 1.0 17 NA NA NA NAS2-40W 10/09/91 1.0 29 NA NA NA NA

Count (n) 65 60 60 60 60Number of Detects 59 0 0 1 9

Number of Non-Detects 9 63 63 62 54Minimum Detection 3.5 0 0 0.006 0.005Maximum Detection 810 0 0 0.006 0.017

Minimum Detection Limit 1 0.005 0.005 0.005 0.005Maximum Detection Limit 10 0.005 0.005 0.005 0.005

Detection Frequency 91% 0% 0% 2% 15%Construction Worker Screening Level 1000 1.4 520 400 420

Rationale 1 ESL(DE) PRG(DE) PRG(DE) PRG(DE) PRG(DE)Chemical of Potential Concern?2 NO NO NO NO NO

Notes:1 Rationale for residential and construction worker screening levels:

PRG = Region 9 U.S. EPA Preliminary Remediation Goal(DE) = Screening Level based on direct exposure

Abbreviations:-0.005 = Sample result below the detection limit indicatedNA = Not AnalyzedTRPH = Total Recoverable Petroleum Hydrocarbons

2 Chemical of potential concern if detected in more than 5 percent of samples and exceeded screening level.

ESL = values from California Regional Water Quality Control Board, San Francisco Bay Region, 2005, Screening for Environmental Concerns at Sites with Contaminated Soil and Groundwater, Interim Final, February. Direct-Exposure Screening Levels, Table K-2 for commercial/industrial worker exposure scenario.

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By: Date:

Figure

Project No.

S:\10100\10181\06_0301_cc\_fig_01.mxd

AVENUEOFTHE

STARS

CONSTELLATION

BOULEVARD

Former WellVault Area

BermedArea

Former ProductionFacilities Area

203

204

205

202 201

200

232B

231

230

229

243

236

264

261

259

273

279

282

206

260

227B/227 211B/C-211B

215B/C-215B

219B/219223B/223

210B/210

214B/214218B/218

222B/222226B/226

209B/C-209B213B/213

217B/217221B/221

225B/225208B/208

212B/212216B/216

220B/220224B/224

235B

234B

233B

228B

245B

244B

242B

241B

240B

239B

238B

237B

255B

254B253B

252B

251B

250B

249B

248B

247B

246B

266B

265B

263B

260B

258B

257B

256B

274B

272B

271B

270B

269B

268B

267B

281B

280B

278B

277B

276B

275B

288B

287B

286B

285B284B

283B

200A

201A

202B

203A

204A

205A

207A

208A

209A210A

211A

212A

213A

214B

215A

216A

217A

218A

219A

220A

221B

222A223B

224A

225A

226A

227A

228A

229A230A

231A

232A

276A275A 274A

273A272A 271A 270A

269A

267A266B

265A264A

263A

262A261A

259A258A

257A 256A

255A254A

253A252A

251A250A

249A

248A247B

246A245A

244A243A

242A

241A240A

239B

238A237A

236A235A

234A

233A

268A

S2-2B

S2-1B

S2-3B

S2-4B

S2-3F

S2-1F

S2-2F

S2-1WW

S2-10W

S2-20W

S2-40W

S2-30W

EXPLANATION

CHEVRON CONFIRMATION SOILSAMPLE (12/27/1990 AND 2/1991)*

CHEVRON FINAL CONFIRMATIONSOIL SAMPLE (2/1991)

LAW/CRANDALL CONFIRMATIONSOIL SAMPLE (2/22/1991)

LAW/CRANDALL CONFIRMATIONSOIL SAMPLE (10/9/1991)

Note:* Locations in Bermed Area marked with a "B"resampled in February 1991. Sample IDsrepeated without the "B" designation.

0 100 Feet

Source: Law/Crandall, 1991.

10181

1

LOCATION OFCONFIRMATION SOIL SAMPLES

10131 Constellation Blvd.Century City, CA