ATTACHMENT 7   PHASE I ENVIRONMENTAL SITE ASSESSMENT PHASE I ENVIRONMENTAL SITE ASSESSMENT ST. ANTON CAPITAL Commercial/Industrial Property 226, 232, 238, 259, 261, 264, 300, 310, 320, 328 and 330 Railway Avenue Multiple Parcels City of Campbell, Santa Clara County, California 95008 May 12, 2014 EEI Project Number STA-71881.1 Corporate Office 2195 Faraday Avenue Suite KCarlsbad, California 92008-7207 Ph: 760-431-3747Fax: 760-431- 3748www.eeitiger.com PHASE I ENVIRONMENTAL SITE ASSESSMENT Prepared for: Mr. Jay D. Coles Development Associate St. Anton Capital 1801 I Street, Suite 200 Sacramento, California 95811 Property location: Commercial/Industrial Property 226, 232, 238, 259, 261, 264, 300, 310, 320, 328 and 330 Railway Avenue APNs 412-03-007, 412-03-006 and 412-03-005, 412-08-006, 412-08-054, 412-08-056, 412-08-061, 412- 08-062, 412-08-065, and 412-07-042 City of Campbell, Santa Clara County, California 95008 Prepared and Edited by: Polly Ivers Project Scientist Reviewed by: Bernard A. Sentianin Principal Geologist EEI 2195 Faraday Avenue, Suite K Carlsbad, California 92008-7207 760-431-3747 EEI Project Number STA-71881.1 TABLE OF CONTENTS GENERAL SITE INFORMATION ........................................................................................................... i EXECUTIVE SUMMARY ........................................................................................................................ ii 1.0 INTRODUCTION................................................................................................................................. 1 1.1 Purpose ....................................................................................................................................... 1 1.2 Scope of Services ....................................................................................................................... 1 1.3 Reliance ...................................................................................................................................... 1 2.0 PHYSIOGRAPHIC SETTING ............................................................................................................ 2 2.1 Subject Property Description...................................................................................................... 2 TABLE 1 Summary of Property Information .................................................................................. 2 2.2 Topography ................................................................................................................................ 3 2.3 Regional and Local Geology ...................................................................................................... 3 2.4 Regional and Local Hydrogeology............................................................................................. 4 2.5 Hydrologic Flood Plain Information .......................................................................................... 4 3.0 SUBJECT PROPERTY BACKGROUND ......................................................................................... 4 3.1 Subject Property Ownership ....................................................................................................... 4 3.2 Subject Property History ............................................................................................................ 5 3.2.1 Historical Use Review ................................................................................................ 5 TABLE 2 Summary of Historical Use Review .................................................................. 6 3.2.2 City/County Directories ............................................................................................. 7 TABLE 3 Summary of Historical Use Review .................................................................. 7 3.2.3 Sanborn Fire Insurance Maps ..................................................................................... 9 3.2.4 City of Campbell Building and Safety Department Files ........................................... 9 3.3 Regulatory Database Search ..................................................................................................... 10 3.3.1 Federal Databases ..................................................................................................... 10 3.3.2 State and Regional Sources ...................................................................................... 11 3.4 Regulatory Agency Review...................................................................................................... 15 3.4.1 Santa Clara County Fire Department ....................................................................... 15 3.4.2 County of Santa Clara Department of Environmental Health .................................. 18 3.4.3 Department of Toxic Substances Control ................................................................ 22 3.4.4 State Water Resources Control Board ...................................................................... 22 3.4.5 Review of Division of Oil, Gas, and Geothermal Resources Files .......................... 22 3.4.6 National Pipeline Mapping System .......................................................................... 22 3.5 Interview with Current Property Owner ................................................................................... 22 3.6 User Specific Information ........................................................................................................ 24 3.6.1 Environmental Liens or Activity and Use Limitations ............................................. 24 3.6.2 Specialized Knowledge ............................................................................................ 24 3.6.3 Valuation Reduction for Environmental Issues ........................................................ 24 3.6.4 Presence or Likely Presence of Contamination ........................................................ 24 3.6.5 Other ......................................................................................................................... 24 3.7 Other Environmental Issues ..................................................................................................... 24 3.7.1 Asbestos-Containing Materials ................................................................................ 24 3.7.2 Lead-Based Paint ...................................................................................................... 25 3.7.3 Radon ....................................................................................................................... 25 3.7.4 Polychlorinated Biphenyls ....................................................................................... 26 TABLE OF CONTENTS (Continued) 4.0 SITE RECONNAISSANCE ............................................................................................................... 26 4.1 Purpose ..................................................................................................................................... 26 4.2 Subject Property ....................................................................................................................... 26 TABLE 4 – Summary of Site Reconnaissance .............................................................................. 29 4.3 Adjacent Properties .................................................................................................................. 30 5.0 VAPOR ENCROACHMENT SCREENING ................................................................................... 30 5.1 Purpose ..................................................................................................................................... 30 5.2 Subject Property Conditions ..................................................................................................... 30 5.3 User Provided Information ....................................................................................................... 31 5.4 Records Review ........................................................................................................................ 31 5.5 Tier 2 Screening ...................................................................................................................... 32 5.6 Findings ................................................................................................................................... 33 6.0 FINDINGS AND OPINIONS ............................................................................................................. 33 7.0 DATA GAPS ........................................................................................................................................ 35 7.1 Historical Data Gaps ................................................................................................................ 36 7.2 Regulatory Data Gaps .............................................................................................................. 36 7.3 Onsite Data Gaps ...................................................................................................................... 36 7.4 Deviations from ASTM Practices ............................................................................................ 36 8.0 CONCLUSIONS .................................................................................................................................. 36 9.0 REFERENCES .................................................................................................................................... 37 FIGURES: Figure 1 – Site Location Map Figure 2 – Aerial Site Map APPENDICES: Appendix A – Résumé of Environmental Professional Appendix B – Assessor’s Parcel Map/Flood Insurance Rate Map/Preliminary Title Report Appendix C – Historical Aerial Photographs/Topographic Maps/City Directory Report/ Sanborn Map Report Appendix D – Environmental Records Search Appendix E – User Provided Information Appendix F – Photographic Log Appendix G –Vapor Encroachment Screen User Questionnaire and Report Phase I ESA – St. Anton Capital May 12, 2014 226-330 Railway Avenue, Campbell, Santa Clara County, California EEI Project No. STA-71881.1 GENERAL SITE INFORMATION Project Information: Commercial/Industrial Property EEI Project Number: STA-71881.1 Site Information: 226, 232, 238, 259, 261, 264, 300, 310, 320, 328 and 330 Railway Avenue APNs 412-03-007, 412-03-006 and 412-03-005, 412-08-006, 412-08-054, 412-08-056, 412-08-061, 412- 08-062, 412-08-065, and 412-07-042 City of Campbell, Santa Clara County, California 95008 Site Access Contact: Mr. Jay Coles, (916) 444-9821 Consultant Information: EEI 2195 Faraday Ave., Suite K Carlsbad, CA 92008 Phone: 760.431.3747 Fax: 760.431.3748 E-mail Address: [email protected] Inspection Date: April 9, 2014; Report Date: May 12, 2014 Client Information: Mr. Jay D. Coles Development Associate St. Anton Capital 1801 I Street, Suite 200 Sacramento, California 95811 Site Assessor: Marc Hachey, PG, CEG, Professional Geologist EP Certification: I declare that, to the best of my professional knowledge and belief, I meet the definition of Environmental Professional as defined in 40 CFR 312.10 (Resume, Appendix A). _________________________________ Bernard A. Sentianin – Principal Geologist AAI Certification: We have the specific qualifications based on education, training, and experience to assess a property of the nature, history, and setting of the subject property. We have developed and performed the all appropriate inquiries in conformance with the standards and practices set forth in 40 CFR Part 312. _________________________________ Bernard A. Sentianin – Principal Geologist i Phase I ESA – St. Anton Capital May 12, 2014 226-330 Railway Avenue, Campbell, Santa Clara County, California EEI Project No. STA-71881.1 EXECUTIVE SUMMARY At the request and authorization of the Client (St. Anton Capital), EEI conducted a Phase I Environmental Site Assessment (ESA) for the property addressed at 226, 232, 238, 259, 261, 264, 300, 310, 320, 328 and 330 Railway Avenue, City of Campbell, Santa Clara County, California. The purpose of this Phase I ESA was to assess the presence or likely presence of any hazardous substances or petroleum products in, on, or at a property: (1) due to any release to the environment; (2) under conditions indicative of a release to the environment; or (3) under conditions that pose a material threat of a future release to the environment (i.e., recognized environmental condition as delineated in ASTM E1527- 13). A De minimis condition is not considered a recognized environmental condition. The subject property is comprised of approximately 3-acres, on ten parcels identified by Assessor Parcel Numbers (APNs) 412-03-007, 412-03-006 and 412-03-005, 412-08-006, 412-08-054, 412-08-056, 412- 08-061, 412-08-062, 412-08-065, and 412-07-042. The subject property encompasses a central 1.55-acre parcel addressed 300 Railway Avenue (APN 412-08-065), adjoining parcels to the south addressed 310, 320 and 328/330 Railway Avenue (APNs 412-03-007, 412-03-006 and 412-03-005, respectively); and adjoining parcels to the north addressed 226, 232, 238, and 264 Railway Avenue (APNs 412-08-006, 412- 08-054, 412-08-56, and 412-08-061/-62, respectively). Also included in the subject property is a single parcel located immediately across Railway Avenue to the northwest of the central parcel and identified as 259 and 261 Railway Avenue (APN 412-07-042). The subject property is located within a mixed-use residential and commercial area in the central portion of the City of Campbell, California. The property is bounded by a mix of residential and commercial development to the north, a multi-family residential complex to the south, the Campbell City Public Works Yard (290 Dillon Avenue) followed by Los Gatos Creek and Highway 71 to the east, and Railway Avenue, followed by a railway to the west. Several commercial businesses, including automobile repair, are located nearby to the southwest at the intersection of Railway Avenue and Kennedy Avenue. According to the City of Campbell Planning Department, the subject parcels are zoned as Planned Development (P-D) and located within the South of Campbell Avenue (SOCA) Special Project Area Plan. According to the Client, a residential redevelopment and mixed-use project is proposed for the subject property. Based on historical records such as aerial photographs, topographic maps, and a previous report, the subject property and adjacent property appeared to be occupied by small structures and orchards from at least 1939. In the 1950s, the current configuration of buildings was developed at the central portion (i.e. 300 Railway Avenue), southern portion (i.e. 310, 320, 328/330 Railway Avenue), and northern portion (264 Railway Avenue) of the subject property. By the 1960s, the current configuration of buildings was developed on the northwest portions of the subject property across Railway Avenue (259/269 Railway Avenue) and the northern portion (226, 232, and 238 Railway Avenue), of the subject property. According to a city directory search, the earliest listing for the subject property was in 1957 for 226 Railway Avenue, which was occupied by a sheet metal facility. Address 238 Railway Avenue was listed in 1963 through 2001 as occupied by a residence. Addresses 259 and 261 Railway Avenue appeared originally to be occupied by plumbing and welding contractors, and beginning in the 1980s, CDS Drywall, Inc., and Railway Distributing, respectively. Address 264 Railway Avenue was first listed in 1985 with Railway Distributing and in 2008 by Foundation Building Materials. Address 300 Railway Avenue (Suites A through E) were listed with commercial occupants, including automobile service and repair shops, auto body shops, metal finishing, painting contractors, electrical contractor, and railway distributing in directories from 1963 through 2001. Addresses 310/320 Railway Avenue was listed with the occupant, Henry Little, from 1970 through 2008. Addresses 328 and 330 Railway Avenue were first listed in 1963 with Wolframs Electric Service and Betra Manufacturing Co., respectively. P&J Service occupied 328 Railway Avenue from 1975 through 1986, and in 1974 through 2001, Glen Dennee was listed under the two addresses. ii Phase I ESA – St. Anton Capital May 12, 2014 226-330 Railway Avenue, Campbell, Santa Clara County, California EEI Project No. STA-71881.1 EEI contacted the County of Santa Clara Fire Department, the County of Santa Clara Department of Environmental Health (CSCDEH), California Department of Toxic Substances Control (DTSC), State Water Resources Control Board (SWRCB), and reviewed other State and Federal databases to determine if the subject property, or any adjacent properties, were listed as hazardous waste generators, underground storage tank release sites (LUST), or as having other environmental concerns (i.e., spills, leaks, or above- ground tanks). The subject property occupant, Swedish Auto Service (300 D Railway Avenue), was listed as a closed release case under the leaking underground storage tank (LUST) and hazardous waste permitting databases. In addition, the subject property occupant, Railway Distributing, Inc. (listed at both 261 and 264 Railway Avenue), was reported under the underground storage tank (UST) and Historical Auto Station databases as the site of a UST removal in 1997 and subsequent site assessment. In addition, the southern portion of the subject property occupied by Henry Little’s Tractor Service (310/320 Railway Avenue) was listed on the LUST database with a closed release case. Additional information reviewed regarding the cases related to the subject property occupants is provided in Section 3.4.2 - County of Santa Clara Department of Environmental Health. Additionally, the subject property occupants, Mikes Auto Body, Sten Nilsson Inc., B&J Automotive, Techmaster Collision Repair, Fleetway Body Shop, and A-Superior Collision Shop, all currently or formerly located at 300 Railway Avenue, were reported under various hazardous waste generator permitting databases (i.e. RCRA-GEN, CUPA, HAZNET, FINDS). A-Superior Collision Shop, Mike’s Auto Body, and Fleetway Body Shop were also listed under the Emissions Inventory (EMI) database. EEI contacted the County of Santa Clara Department of Environmental Health (CSCDEH) concerning the closed LUST cases associated with the subject property. EEI reviewed a 1990 site investigation report (On-Site Technologies, Inc.) associated with 261 Railway Avenue, which at the time of the report was occupied by a drywall company and used for storage and parking by Railway Distributing, Inc. Background information indicated that a former tenant had installed a 1,000-gallon gasoline UST at the site in 1972. The report stated that previous subsurface investigations had been performed in 1986 near the sump at the rear (west) end of the site near the area of past drum storage as well as the UST location. The data from two soil samples collected near the sump indicated concentrations of oil and grease at 102 ppm and 128 ppm. Based on these results, additional soil samples were collected near the sump and were tested for purgeable organics. Benzene, Toluene and Xylene (BTX) were detected in the soil samples at concentrations of 7, 46, 58, and 110 ppm. Data from a single soil sample taken from below the 1,000-gallon UST located at the southeastern edge of the site indicated non-detectable levels of total volatile Hydrocarbons as gasoline, and BTX. Based on these results the Campbell Fire Department allowed the tank to be slurry filled. The 1990 phase of the investigation was conducted in response to a letter from the Santa Clara Valley Water District dated November 6, 1989, requesting further site investigation. The scope of service was to assess the vertical extent of previously detected petroleum hydrocarbons in the soil adjacent to the sump and the drum storage area. The work consisted of drilling one borehole to a depth of 50 feet and obtaining soil samples at 5-foot intervals. The depth of groundwater was found to be greater than 51 feet (and maybe considered deeper) and there was no evidence of apparent soil contamination. Therefore, the borehole was not converted to a groundwater monitoring well, and drilling and sampling was terminated. According to the report, soils in the borehole contained oil and grease concentrations greater than 100 ppm and less than 270 ppm to a depth of 26 feet. From 26 feet to 51 feet, oil and grease concentrations were at non- detectable levels, except at 36 feet where 46 ppm was reported. PCBs were not detected in the soil with oil and grease concentrations. iii Phase I ESA – St. Anton Capital May 12, 2014 226-330 Railway Avenue, Campbell, Santa Clara County, California EEI Project No. STA-71881.1 According to the report, a silty clay occurred from 30 feet to 41 feet and appeared to be a barrier to vertical migrations of oil and grease. The report added that BTX was not detected in any of the soil samples from the single borehole, therefore the previously detected BTX appeared to be localized in near surface soils at the sump. Based on this and the previous analytical results, the consultant stated that it was unlikely that oil and grease had or would migrate vertically and impact groundwater beneath the site, because of the clay layer and great depth to groundwater. The consultant stated that no further work was recommended, and a request was made for the appropriate regulatory agencies to review the information gathered for the purpose of case closure. A letter from the Santa Clara Water District dated June 18, 1992 pertained to the above referenced unauthorized release of total oil and grease near a sump and an above ground drum storage area. The letter stated that the contamination appeared to be the result of above ground storage; therefore, the water district referred the case to the spill response staff with the RWQCB. The letter indicated that the site was previously listed as a Fuel Leak Site on the Water Districts database. However, the water district stated it would remove it from their database, because the results of analyses conducted on the single soil sample collected from beneath a 1,000-gallon UST at the site indicated that petroleum hydrocarbon contamination was not present in detectable concentrations and there did not appear to have been a release from the tank (this UST was subsequently filled with concrete and closed in place as stated above). EEI also reviewed CSCDEH documents related to a former UST located at the subject property occupied by Railway Distributing (264 Railway Avenue), a drywall and construction supply business. According to a tank closure report prepared by Piers Environmental Services (PIERS) on July 24, 1997, a 550-gallon gasoline UST was installed at the site in 1955 or 1956. The tank was used to fuel company vehicles up until approximately 1988, when it was reportedly decommissioned and filled with concrete. Reportedly, there was no permit for tank closure, as the property owner at the time was unaware of any regulatory requirements. The subsequent property owner was notified by the Central Fire District (CFD) that the tank would need to be properly permitted and closed in accordance with regulatory standards. Given that the tank had been filled with concrete and was positioned in very close proximity to the adjoining building, the CFD agreed to allow the tank to be closed in-place provided that soil sampling was performed beneath the tank to confirm that no significant release of hydrocarbons had occurred. In June 1997, PIERS drilled two exploratory borings at either end of the UST. Two soil samples collected from a depth of 10 feet bgs (EB-1 and EB-2) were analyzed by EPA Standard Method 148.1 for Total Recoverable Petroleum Hydrocarbons (TRPH), and EPA Method 8010/8020 for TPH-g, and Benzene, Toluene, Ethyl Benzene, and total Xylenes (BTEX). The analytical results of the soil samples from both borings EB-1 and EB-2 were found to contain 230 ppm and 190 ppm, respectively, of TRPH. No TPHg or BTEX constituents were detected in either of the samples. Given this, PIERS stated that the data suggested that there was likely no significant release of gasoline hydrocarbon constituents from the UST. PIERS stated that the detectable concentrations of TRPH could be attributable to naturally occurring organic matter; and the only way to determine if the TRPH is from a petroleum source was to perform a silica-gel clean-up during the extraction process. As this step was not performed by the lab, PIERS stated that the results could well be indicative of organic matter. In addition, PIERS stated that the samples containing TRPH contained virtually no volatile components. According to PIERS, no significant environmental impact appeared to be present at the site resultant from the existence of the former fuel tanks. No further investigation was recommended and PIERS requested that the case be closed. iv Phase I ESA – St. Anton Capital May 12, 2014 226-330 Railway Avenue, Campbell, Santa Clara County, California EEI Project No. STA-71881.1 A Santa Clara County Fire Department (SCCFD), case closure letter dated August 15, 1997, confirmed the UST system at 264 Railway Avenue was closed in accordance with their requirements for UST system closures. Based on the available information, the letter stated that there are no further fire department requirements for the UST system closure. The letter noted that the fire department requirement for proper closure did not include soil remediation activities, and further added that the Santa Clara Valley Water District be contacted for any necessary remediation requirements. Swedish Auto Service, 300 D Railway Avenue, (Case No. 14-085). According to a Case Closure Summary report, a 500-gallon waste oil UST was removed from the property in March of 1987. At that time, one soil sample was collected at approximately 8.5 feet below ground surface (bgs) underneath the fill end of the tank. The sample contained Total Petroleum Hydrocarbons (TPH) as diesel (TPH-d), and motor oil and grease (TPH-mo) at concentrations of up to 110 and 160 parts per million (ppm), respectively. Dichlorobenzene was detected in concentrations of up to 0.033 ppm. Benzene was not detected above laboratory detection limits. The case summary indicated that based on the tank conditions upon removal, consultants observations, and excavation pit soil sample results, the CSCDEH determined that soil contamination was present only in low concentrations. The CSCDEH added that the results of the soil and groundwater investigation, which was conducted in accordance with the RWQCB Guidelines, indicated that the beneficial uses of groundwater should not be threatened by the low levels of residual soil contamination left in-place at the site. The summary indicated that no groundwater monitoring wells were installed, and no data regarding depth to groundwater or flow direction were reported. A CSCDEH tank closure letter, dated November 14, 1995, documented the completion of the site investigation and remedial action for the UST formerly located at the site (i.e. central portion of the building at 300 D Railway Avenue). The letter stated that based on the available information, no further action related to the UST release was required. The subject property occupied by Henry Little Tractor Service (310/320 Railway Avenue), reported a diesel fuel release in November 1990, which reportedly impacted the soil only. EEI reviewed a Santa Clara County Water District, UST Case Closure letter and case closure summary for the site (Case No. 90G), dated January 1, 1995. The case closure summary report indicated that a release occurred during tank removal of two (2) 4,000-gallon and one (1) 2,000-gallon UST. A description of the remediation activities indicated that high concentrations of contamination, up to 1,100 ppm diesel and 150 ppm gasoline, were detected at 8 feet bgs underneath the fill end of the 2,000-gallon gasoline tank. Additional soil was excavated from below the west end of the fill pipe area, and a confirmation sample was collected from 12 feet bgs. Analytical results indicated the sample contained non-detectable concentrations of contamination. The minor concentrations of contamination were left in-place below the 4,000-gallon gasoline tank. The summary indicated that no groundwater monitoring wells were installed; however, the depth to groundwater was estimated to range between 60 feet to 98 feet bgs. The groundwater flow direction was reported as unknown. The closure letter confirmed the completion of the site investigation and remedial action for the UST and stated that based on the available information, no further action related to the UST release was required. A review of Santa Clara County Fire Department records indicated that in January 1988, a single 1,000 gallon gasoline UST was removed from the subject property (328/330 Railway Avenue). An April 1988 Tank Removal Report indicated that no product and no groundwater were encountered during excavation. Two samples were taken from the bottom of the excavation (south end SS-1, north end SS-2); and collected from one-foot below the bottom of the tank excavation. Results of the laboratory analyses indicated that the levels of TPH as gasoline were below the action levels of the RWQCB. No indication of a closure letter was provided in the fire department files. The presence of the former UST and subsequent site assessment represents a historical REC. v