Corrective Action Program Ewan Moffat County of San

Corrective Action Program Ewan Moffat County of San Diego Department of Environmental Health Site Assessment & Mitigation Program

Corrective Action Designation O On February 28, 2014, the Department of Toxic Substances Control (DTSC) delegated authority to DEH, as the local Certified Unified Program Agency (CUPA), to oversee Corrective Action at permitted facilities in the County of San Diego. O Applies to releases of substances from CUPA permitted facilities.

SAM Programs O Local Oversight Program (LOP) O Voluntary Assistance Program (VAP) O Corrective Action Program (CAP)

Corrective Action (CA) Corrective Action does not apply to: O Releases from non-CUPA permitted sources O Small spills and releases that are cleaned up as part of routine housekeeping.

Sources of Corrective Action Cases O Analytical data submitted in compliance with Monitoring Well Program permits at sites that are or were CUPA permitted facilities O Referrals from Hazardous Materials Division, including routine inspections and PBR/CA closures O Recalcitrant Voluntary Assistance Program cases that are or were CUPA permitted facilities

When is Corrective Action Required? Inspections Phase II Environmental Assessment PBR/CA Closure Suspected Release No Further Investigation Required Clean Closure Further Investigation Required Corrective Action Required

Corrective Action Process O Responsible Party (RP) fills out Corrective Action Consent Agreement O If RP won’t sign Consent Agreement, DEH will issue a Corrective Action Order O Deposit account is funded O RP sets up Financial Assurance

Title 22 CCR Section 68400. 16 Requires a corrective action process that fulfills the following: O Site screening using Preliminary Endangerment Assessment (PEA) manual O Adequate site characterization of release and risk assessment that evaluates risk O Cleanup that is protective of human health and environment (10 -6 risk level)

Summary O CAP for past or present CUPA facilities with significant releases to the environment O Enforcement, if necessary, to ensure corrective action is performed O Similar to VAP goals (adequate cleanup to environment and no health risks to future and present occupants)

Case Study - Next Presentation Kyocera America, Inc. 11620 Sorrento Valley Road, San Diego, CA 92121

? ? Questions? Ewan Moffat, EHS-II, PG, Chg ewan. moffat@sdcounty. ca. gov (858) 505 -6856 James Clay, CAP Program Facilitator james. clay@sdcounty. ca. gov (858) 505 -6969 ?