BURLINGAME HIGH SCHOOL (41820008) on toxic waste site

Site History

Envirostor (State of California) page 400 CAROLAN AVENUE BURLINGAME, CA 94010-2708

Google Map

Map of the site is on page “The 22-acre site located at 400 Carolan Avenue, in Burlingame. It is the existing Burlingame High School (built in the late 1910s). DTSC reviewed a Phase I Environmental Site Assessment (Phase I) and determined that a Preliminary Environmental Assessment (PEA) was required.

A Preliminary Environmental Assessment (PEA, 2003/04) investigated the site for metals, organochlorine pesticides, polychlorinated biphenyl (PCB), total petroleum hydrocarbons, volatile organic compounds and metals. The PEA report identified lead and PCB around the main building, and elevated arsenic in the athletic field. DTSC issued further action for Lead/PCB, and additional investigation for the arsenic.

Supplemental site investigations defined the extent of lead impacted soils and identified elevated levels of arsenic in soils in various areas of the campus.
A Removal Action Workplan (RAW) for lead and PCBs was approved for implementation in December 2005 for areas around the main building. The removal began in January 2006 and was completed in June 2007. Financial hardship caused delays in the completion of the removal. Once financial issues were resolved, the District took confirmation samples to confirm clean-up goals were met.

A second RAW was developed to address approximately 3,000 cubic yards of arsenic impacted soil found throughout the site. To complete remedial activities, the site was divided into seven areas, identified as Areas A through G. A fence was erected in April 2005 around the front lawn area (Area E) and rear soccer field (Area G) to restrict access to the areas due to slow progress towards removal of impacted soil. Source of the arsenic is unknown. Fieldwork began on December 2007. The remediation areas are: Area A-courtyards; Area B-Shot Put; Area C-Landscaped areas; Area D-track side and Carolyn Avenue [D1 (near gym) and D2 (near Carolan Avenue)]; Area E-Front Lawn; Area F-Parkway [F1 (near the vicinity of the school track and softball fields) and F2 (near the vicinity of the front lawn)]; and Area G-fence line and Home Economics lawn [G1 (fence line near field), G2 (near Home Economic Building and Multi-use Building), and G3 (fence line near classrooms)].

On October 27, 2008, DTSC developed and approved an Explanation of Significant Difference (ESD) for the project. The ESD serves as a bridging document to explain that a Land Use Covenant (LUC) is needed for this project, since a LUC was not mentioned in the removal action workplan. A LUC is needed since arsenic at levels not suitable for unrestricted use will remain on the campus; however, barriers are in place to eliminate contact with the arsenic impacted soil.

On October 2008, DTSC approved the removal action completion report for lead/PCB and certified that there is no longer a risk posed by lead/PCB at the site.

The Remedial Action Completion Report (RACR) for Arsenic documents the excavation, encapsulation, and off-site disposal of soil contaminated with arsenic. Arsenic-impacted soil remains at Areas C, D2, E, F, and G3. Where back filling occurred, a marker (orange plastic mesh or metal gopher mesh) was placed over the remaining arsenic-impacted soils prior to back filling. All arsenic mitigation activities were completed in January 2009. Area A and G1 were the only areas where arsenic impacted soil was able to be completely removed, and cleanup goal was met. Areas C, D2, E, F and G3 are required to be managed in an Operation and Maintenance (O&M) Plan. In addition, some sidewall samples in Areas B, D1 and G2 contained arsenic concentrations above the Site clean up screening level and will also be required to be managed in an O&M Plan.

On August 31, 2009, DTSC approve the RACR as final; however, certification that all response actions have been completed will be issued after DTSC reviews and approves the final O&M Plan. On May 6, 2010, DTSC issued a clarification of the RACR approval letter.

DTSC conducted an Arsenic Annual Inspection on June 28, 2010. A few minor issues were found. Neighboring property owners have access gates through the property fence and were observed walking over the cap (wood chips) at Area G3 and C (along the property fence line behind Building I). Students maybe cutting across a restricted area. Portions of Area C require additional bark or plant coverings: along Building C and D, along the library, in the construction area near the gym (irrigation system was turned off and the landscaping cover died), near the tennis courts, and the northern parking area near the tennis courts. The NOA storage area needs additional bark. Area F2, located along the parkway on Carolan Avenue, needs additional crushed rock around the tree bases. The initial Arsenic Awareness training and the Arsenic O&M Inspection training were not conducted, however, no arsenic intrusive work was performed this last year. Periodic inspection of the capped areas were not conducted this last year. On December 20, 2010, DTSC received the 2010 Annual Inspection report. DTSC reviewed the 2010 Annual Inspection report and identified issues that require clarification or modification. In June 2011, DTSC approved the report after the District submit additional information as an addendum.

On June 30, 2011, DTSC conducted an annual inspection. During the annual inspection the following issues were observed: 1) exposed soil on several capped areas (Area C, Area E, and Area F2) requiring ground cover (e.g., wood chips or crushed rocks); 2) Building D and planter area were demolished; and, 3) construction of a new structure over former Building D has occurred and is almost complete. On July 20, 2011, DTSC issued a letter requesting that these issues be addressed and information be submitted.

On August 4, 2011, DTSC issued a conditional approval [need to update figures] of the Operations and Maintenance Plan (Kleinfelder, Inc., December 3, 2010). On September 13, 2011, DTSC received the updated O&M sections addressing some of DTSC’s comments on the conditional approval letter. On July 10, 2012, DTSC received the final O&M (Locus Technologies, July 2012) addressing all the issues in the conditional approval letter.

In October 2011, DTSC received the draft 2010-2011 Annual O&M Report. The 2011 Annual Report documents the inspection of the engineering controls for arsenic containing soils at the site for the period of September 1, 2010 through August 31, 2011 and describes the actions required and/or taken by a qualified District staff for repair or mitigation of engineering controls. DTSC issued comments on the 2010-2011 Annual O&M Report and awaiting the District’s response. On May 3, 2012, DTSC approved the Revised 2011 Arsenic Annual Inspection Summary Report.

On June 18, 2012, DTSC participated with the District and their consultant on the 2011-2012 Annual O&M Inspection. No significant issues were observed during the site walk through. On August 13, 2012, DTSC received the 2012 Arsenic Annual Inspection Summary Report. On September 4, 2012, DTSC approved the Annual Inspection Summary Report.

In September 2012, DTSC forwarded to the District a draft final LUC for their review and signature. On December 11, 2012, DTSC mailed the fully executed LUC to the District for recordation with the County of San Mateo. On January 4, 2013, the LUC has been finalized and recorded with the County of San Mateo. Annual inspections will be conducted at the site to ensure that the cap is still in place.

During the first week of July 2014 On July 10, 2013, DTSC participated during the annual inspection with the District and their consultant. During the annual inspection, some areas require additional wood chips to cover exposed soil (i.e., Area C – Landscaped area around tennis courts). On August 12, 2013, DTSC received the 2013 Arsenic Annual Inspection Report (annual report). On September 4, 2013, DTSC issued comments regarding the annual report. On October 3, 2013, DTSC approved the annual report.

On December 2, 2013, the Arsenic Coordinator notified DTSC of Arsenic-Intrusive Work. The District’s project is the demolition of the slab for Building F, the former Home Economics Building, at the Site. The demolition will result in excavation to a depth of 18 to 24 inches across the entire project site. The construction is proposed to start December 16, 2013 and will be completed by approximately January 24, 2014. The District stated in the notification that the DTSC approved SOP will be followed throughout the project, including employing dust control measures to prevent potential exposure to the disturbed soil.

On July 1, 2014, DTSC published a notice on the Bay Area News Group for the start of the 5-year Review at the Site. On July 9, 2014, DTSC participated on the first 5-Year Review of the cap system with the District representatives and their consultant. On August 26, 2014, DTSC received the draft 5-Year Report. DTSC issued comments on the 5 Year report and for the revision of the O&M plan on September 17, 2014.

On December 3, 2014, DTSC approved the Revised 2014 Arsenic Five-Year Summary Report which also included the Land Use Covenant (LUC) Report as an attachment. Part of the 5-Year Review process is the updating of the O&M Plan. On April 23, 2015, DTSC received the updated O&M Plan for review. On May 12, 2015, DTSC issued comments on the draft updated O&M Plan. Changes in the O&M Plan included: elimination of the 5-year review mailings to faculty, students, staff, and community but continue public notification issued by DTSC in the local paper, as well as posting at the school and on the website; reporting frequency from every year to every two years; and, administrative changes such as contact names, telephone numbers, etc. Based on the results of the 5-Year Review, it appears the remedy is functioning as designed, and is being maintained appropriately. The remedy continues to be protective of human health and the environment. On June 9, 2015, DTSC approved the updated O&M Plan.

On July 22, 2015, DTSC participated with the District and their consultant conduct the annual O&M inspection. No significant issues were observed during the site walkthrough. DTSC reminded the District that the LUC report (checklist) must be submitted to DTSC since there is no Inspection Summary Report in 2015. On January 15, 2016, the DTSC received the completed LUC monitoring checklist.

On June 14, 2016, DTSC participated during the annual inspection of the capped area with the District and their consultant. No significant issues were observed during the site walkthrough. On September 8, 2016, DTSC received the 2015 and 2016 Arsenic Biennial Summary Report (Biennial Report) for review and comment. On September 28, 2016, DTSC approved the Biennial Report (August 9, 2016 Revised September 1, 2016). The next annual inspection is to be completed on or before June 30, 2017. The next biennial report is scheduled to be completed by August 31, 2018 with the second annual inspection conducted 60 days prior.

On June 14, 2017, DTSC participated during the annual inspection of the capped area with the District and their consultant. No significant issues were observed during the site walkthrough. On August 30, 2017, DTSC received the 2017 annual compliance letter (Compliance Letter). The Compliance Letter documents the inspection of the capped areas for the period of July 1, 2016 to June 30, 2017 verifying compliance with the environmental restrictions stated in the Land Use Covenant (LUC, recorded January 4, 2013); no work was done on the capped areas. The 2017 annual inspection and 2017 annual compliance letter will be reported in the Arsenic 5 year Summary Report.

On May 14, 2018, DTSC participated during the second 5-Year site inspection. Cap thickness were measured and were all adequate. On July 13, 2018, DTSC received the draft 2018 Arsenic Five-Year Summary Report (2018 5-Year Report ) for review and comment.
The 2018 5-Year Report evaluates if the remedy:
a) remains protective of human health and the environment;
b) is functioning as designed; and,
c) is maintained appropriately by O&M activities.
The 2018 5-Year Report also discusses the inspection of the engineering controls and describes the actions taken/required by qualified San Mateo Union High School District (District) staff to maintain the engineering controls.

The 2017 annual inspection and the Five-Year inspection occurred on June 14, 2017 and May 14, 2018, respectively. In addition, the Land Use Covenant (LUC) Reports are included in the 2018 5-Year Report. The LUC Reports document the inspections of the capped property for the periods of July 1, 2016 to June 30, 2017 and July 1, 2017 to June 30, 2018 verifying compliance with the environmental restrictions stated in the LUC. On July 19, 2018, DTSC issued comments on the draft 2018 5-Year Report.

Based on the results of the 5-Year Review, it appears the remedy is functioning as designed, and is being maintained appropriately. The remedy continues to be protective of human health and the environment. On September 10, 2018, DTSC approved the revised 2018 5-Year Report and the updated O&M Plan.

Updated O&M Plan:
Arsenic Training Awareness: Training Requirements, Trainer Requirements, O&M Inspections
O&M Inspections: Periodic, Unplanned Events, Annual Inspections
Notification, Record Keeping and Reporting
1) Annual inspections
2) Public Right to Know
3) Notification/Completion Report for Arsenic-Intrusive Work
4) Biennial Inspection Reports, (2019-2020)
5) 5 year Review Reports (2022)
6) Record Keeping and Record Retention

Project Manager Change Letter
On November 13, 2019 the DTSC Project Manager changed from Bud Duke to Letitia Shen.

2019-2020 Biennial O&M Reporting
On May 21, 2019 DTSC provided oversight for 2019 O&M Inspection with District and Consultant.
On May 7, 2020 District and Consultant performed 2020 O&M Inspection.
On June 26, 2020 DTSC received the “2019 and 2020 Arsenic Biennial Summary Report” (Locus Technologies, Inc. [Locus] June 26, 2020).
On July 8, 2020, DTSC approved the “2019 and 2020 Arsenic Biennial Summary Report”.

The next annual inspection May 2020,
LUC report due 08/2020

Updated 07/13/2020 LS”

Deed Restriction / Land Use Covenant:

Envirostor (State of California) Deed Restriction Page

Land Use Covenant   1/4/2013  

Map of the locations of the contamination for the High School is on page 22 of the Land USe Covenant





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