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Appendix E WSP 2014 Phase I Sears Addendumjmmmwsp June 26, 2014 Via E -Mail Ms. Rochelle Lopez Sand Hill Property Company 2882 Sand Hill Road, Suite 241 Menlo Park, CA 94025 Re: Limited Phase I Environmental Site Assessment of Sears/Bay Club Retail Facilites in the Vallco Shopping Center in Cupertino, California Dear Ms. Lopez: At the request of the Sand Hill Property Company (Sand Hill), WSP Services, Inc. (WSP) conducted a limited Phase I environmental assessment of the Sears/Bay Club Retail Facilities located within the Vallco Shopping Center in Cupertino, California. WSP completed a Phase I environmental assessment report dated January 7, 2014 of the Vallco Shopping Center. The Sears facilities, which include the Sears retail store/Bay Club fitness facility building, and the Sears Automotive Center, were not covered in the Phase I report and a detailed review and walkthrough of these facilities at that time was unable to be conducted due to confidentialy considerations. Limited Phase I Envirommnetal Site Assessment On June 12, 2014, Richard Freudenberger of WSP, accompanied by Rochelle Lopez of Sand Hill, conducted a site visit of the Sears facilities. Tyler Davis, quality maintenance assistant for Sears, was presnt and provided information about the Sears facilities. Mr. Tyler has worked for Sears for six years including 4.5 years at the Vallco location. The Sears retail store (with approximately 120,000 square feet of retail floor space) handles, stores, and sells a variety of retail materials and products unique to their place of business. There is a basement and three retail floors. No major quantities of chemicals or hazardous materials are currently stored onsite. Sears retails small containers of gasoline/oil mixtures for use in lawn equipment and sells small propane gas containers. Paints and small quantities of cleaners are stored within the basement office of Mr. Davis. There is also a small dental office (Cupertino Square Dentist) in the Sears retail building that operates independently of Sears. The Bay Club occupies an area (approximately 140,000 square feet of floor space) within the Sears retail building. WSP Group plc Offices worldwide WSP Services, Inc. 2025 Gateway Place, Suite 435 San Jose, CA 95110 Tel: (408) 453-6100 Fax: (408) 453-0496 www.wspenvironmental.com The Bay Club leases the space from Sears and renovated the area in early 2013; the Bay Club is a fitness center with various exercise facilities and equipment, a Starbucks shop, a whirlpool lounge, a dry sauna, and a steam room. Small quantities of chemicals for treatment of water in the whirlpool are stored on the portion of the rooftop above the Bay Club. The Sears Automotive Center (approximately 14,000 square feet with a basement area) is a separate building located in the parking area northwest of the Sears retail building. Construction of the Sears buildings was completed in October 1970. Bulk product oil is stored in aboveground contained tanks within the eastern portion of the Automotive Center. Waste oils are contained withn an aboveground tank in the same area. Several drums of oils and lubricants within containment are stored in the same area. Product oil is delivered and waste oil is removed by Hunt and Sons. The Automotive Center stores tires, batteries, and small quantities of retail oils and lubricants in the basement.There are hydraulic lifts within the Automotive Center and there are several unidentified surface caps for access to potential below ground equipment installations in the paved parking area south of the Automotive Center. The Sears Automotive Center is listed on the leaking underground storage tank (LUST) database as a closed case with no further action required. Based on a review of the Geotracker website, four gasoline and two motor oil USTs were removed from the Sears Automotive Center site in 1985. Dispenser islands and product lines were removed from the site in 1994. Seven borings were installed and sampling was conducted in soil and groundwater in 1999 to assess hydrocarbon concentrations at the site. Groundwater was not encountered in any of the borings at a depth of 44 feet below ground surface (bgs). Concentrations of ethylbenzene, total xylenes, and lead were reported below regulatory action levels and the site was granted case closure on December 6, 1999. The LUST case for Sears is an historic recognized environmental conditions (REQ, but does not appear to pose any immediate environmental concern to the subject property and no further investigation or corrective action is currently required. No heating systems are employed within the Sears and Bay Club areas and the Automotive Center. The building AC systems contain Freon -based cooling systems and undergo preventative maintenance by Superior Mechanical Sytems, Inc. Schindler maintains the elevator and escalator systems. There is a natural gas powered emergency generator located in the basement of the Sears retail building. Potable water is provided to the Sears buildings by Cal Water. Wastewater is treated in the city of San Jose wastewater treatment plant. No wastewater permits are required for the collective sanitary wastewater discharge from the Mall. There are two small sanitary wastewater lift station systems in the basement of the Sears retail building. There are reportedly no grease traps in the Sears/Bay Club building. Storm water that contacts the areas surrounding the Sears/Bay Club building and the Automotive Center infiltrates into small landscaped soil areas, runs off by sheet flow or along curbs and gutters into storm drains within the parking areas. No evidence of stains or stressed vegetation was observed. No storm water permit is maintained and none appears to be required. No sources of air emissions that require air permits appear to be present within the Sears buildings. Electric power and natural gas are supplied by Pacific Gas & Electric (PG & E). There is a PG & E transformer on the south side of the Sears/Bay Club building In 2003, Ceres Associates reported that, according to PG&E, PCBs were removed from the transformers within the Vallco Center between the 1970s and early 1980s. No leaks or stains were observed. Based on WSP's observations, it is unlikely that there are any PCBs associated with the transformer near the Sears/Bay Club building. WSP was requested to determine if any readily observable building materials have the potential to contain asbestos. WSP was not contracted to perform a comprehensive asbestos survey or testing of materials for asbestos content. The Sears buildings were constructed in 1970, when asbestos -containing material (ACM) was used in building materials. The Occupational Safety and Health Administration (OSHA) requires facilities to presume that any surfacing material and thermal system insulation in buildings constructed before December 31, 1980, contain asbestos, unless testing or other information demonstrates otherwise. Additionally, any vinyl flooring installed before December 31, 1980 must be presumed to contain asbestos unless testing or other information demonstrates otherwise. The application of molded and wet -applied asbestos building materials, used in many decorative applications, was banned in 1975. In 1976, ACM used for mechanical system insulation was prohibited. All acoustical and decorative applications containing asbestos were banned in 1978. In 1989 the EPA instituted a ban of many types of non -friable ACM that was to occur in phases through 1997; however, in 1991, the phased ban was overturned by the Fifth Circuit Court of Appeals. Subsequently, only flooring felt; rollboard; and corrugated, commercial and specialty paper were banned in the U.S. Therefore, many types of non -friable building materials may still contain asbestos. These products include, but are not limited to, roofing felt, vinyl asbestos floor tile, ceiling tiles, transite flat sheet, transite shingles, roofing coatings, and transite pipe. An asbestos survey was reportedly performed in the Sears retail/Bay Club building and the Automotive Center in 2004 and asbestos containing materials (ACM) were identified in several areas. In September 2011, as a result of a water intrusion incident, a focused and limited asbestos survey was performed and removal of ACM in the area of the water intrusion was conducted. WSP observed suspect ACM (pipe insulation, floor tiles, wallboard, etc.) in the Sears retail building and notices were posted in several areas of the retail building as to the presence of AC fibers. In 1978, the U.S. Consumer Product Safety Commission lowered the permissible levels of lead contained in paints and prohibited application of lead-based paint to housing constructed or rehabilitated with federal assistance. Paint manufacturers complied by lowering or eliminating lead content from paint products sold for residential use. Based on the age of the Sears buildings (constructed in 1970), lead-based paint may be present. However, many of the interiors of the retail spaces have been refurbished and painted several times. The presence of lead-based paint can only be confirmed through testing of the painted surface/layers. Findings and Recommendations The following provides major findings and recommendations associated with environmental issues identified during the inspection of the Sears Retail Store, Bay Club, and Sears Automotive Center at the Vallco Property on June 12, 2014. 1. Before disturbance of areas as part of any demolition or redevelopment of areas where suspect or identified ACM or lead based paint may be present, it may be desirable to conduct a more complete ACM survey and lead based paint survey, and/or prepare an ACM operation and maintenance (O & M) plan based on the existing identification of ACM. These steps will further document and identify the presence of ACM or lead based paint within the Sears buildings and/or ensure that any future maintenance, renovation, or demolition activities do not pose a risk of exposure to lead based paint and friable ACM, and that any lead based paint and ACM will be properly handled and disposed of according to regulatory requirements. 2. Four gasoline and two waste oil underground storage tanks were removed in 1994 and the site was given a No Further Action status by the Regional Water Quality Control Board in 1999. The LUST case for Sears is an historic recognized environmental condition (REC), but does not appear to pose any immediate environmental concern to the subject property and no further investigation or corrective action is currently required. 3. Based on the inspection of the Automotive Center, several below ground hydraulic lifts are present in the service area of the Center.. Because of the former presence of the underground storage tanks, the hydraulic lifts currently in use, and the possibility of underground installations, any future disturbance or investigation in the area of the Sears Automotive Center (removal of the building and/or excavation) should be performed with care and an awareness of the potential for petroleum or chemical releases in these areas. 4. Several unidentified surface caps for access to potential below ground equipment installations were identified in the paved area south of the Automotive Center and an initial inquiry to Sears did not yield information as to the purpose of the caps or possible subsurface installations. In order to understand any subsurface implications before demolition or redevelopment of the Automotive Center, it may be desirable to undertake a simple visual inspection through removal of the four caps to attempt to determine the purpose/presence of any underground installations such as monitoring wells, utility clean - outs, valves, etc. beneath the caps. 5. There do not appear to be any major issues associated with hazardous and non -hazardous waste handling, storage, or disposal within the Sears buildings and the Bay Club. Additionally, there are no major environmental findings associated with sanitary or other wastewaters, or air emissions, associated with the Sears buildings and the Bay Club. 6. There does not appear to be any other recognized environmental conditions (RECs) associated with the Sears buildings or the Bay Club. Please call me at 408.453.6100 if you have any questions or require additional information. Sincerely yours, Richard E. Freudenberger Executive Vice President REF:aw