SDCDEH CASE NO. H02358-002 Response Letter 2012-04-04OF.
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JACK MILLER DEPARTMENT OF ENVIRONMENTAL HEALTH ELIZABETH POZZEBON
DIRECTOR LAND AND WATER QUALITY DIVISION ASSISTANT DIRECTOR
P.O. BOX 129261, SAN DIErO, CA 92112 -9261
858 - 505 - 6700 /FAX 858- 505- 684811- 800- 253 -9933
www.sdedeh.ora
April 4, 2012
Ms. Stephanie Kellar
City of Encinitas
Engineering Department
505 South Vulcan Avenue
Encinitas, CA 92024
Dear Ms. Kellar:
VOLUNTARY ASSISTANCE PROGRAM — DEH CASE NO. H02358 -002
RESPONSE LETTER
HALL PROPERTY COMMUNITY PARK
425 SOUTH SANTA FE DRIVE, ENCINITAS, CALIFORNIA
Staff of the Department of Environmental Health (DEH) reviewed the documents titled Soil Reuse
Plan (Revision 3) and Community Health and Safety Plan (Revision 3), both dated March 29, 2012,
prepared by SCS Engineers.
The reports summarize existing site conditions, propose the management and reuse of
approximately 46,000 cubic yards of pesticide impacted soil, and outline efforts to protect potential
environmental, health, and safety impacts associated with soil management. Based on the
aforementioned reports, the consultant is proposing the following:
• Based on extensive soil sampling efforts, the consultant estimates that approximately 46,000
cubic yards of soil, associated with seven areas of the site, are impacted with legally applied
pesticides above residential California Human Health Screening Levels (CHHSLs), which
the City of Encinitas is proposing to mitigate prior to the development of a 43 acre
community park.
• The consultant is proposing to excavate and temporarily stockpile impacted soil at the site
before placing it into two distinct excavations on the southern portion of the site with a
combined capacity up to approximately 70,000 cubic yards.
• Adjacent property owners and tenants will be notified in advance of the start of remediation
activities and signage will be posted and maintained at numerous locations on the site
perimeter.
• Handling of impacted soil will not occur unless the consultant is onsite and overseeing its
management until excavation activities are complete and impacted soil is capped with a
minimum of 5 feet of clean soil.
"Environmental and public health through leadership, partnership and science"
Ms. Stephanie Kellar - 2 - April 4, 2012
• Pesticide impacted soil will be placed a minimum of 10 feet above estimated groundwater
levels and a minimum of 5 feet below any proposed or future subsurface structure.
• Impacted soil associated with open excavations, stockpiling, and backfilling activities will
remain covered when not in use and at the end of each day until confirmation sample results
indicate remediation activities are complete or until the five foot clean soil cap is in place
above impacted soil.
Air monitoring activities, including the collection of baseline air samples and a correlation
evaluation between airborne particulate levels and airborne constituent of concern (CoC)
concentrations, will be conducted from the first day of impacted soil disturbance until the five
foot soil buffer is in place. Air monitoring will also include hourly airborne particulate
measurements during impacted soil handling and weekly airborne CoC concentration
sampling at proposed air monitoring stations. Wind direction will be recorded at least hourly
at the site and DEH will be notified of any airborne CoC exceedances the first business day
following the exceedance.
Impacted soil reused at the site will be surveyed and a deed restriction will be prepared,
approved by DEH, and recorded with the County Assessor's Office before site closure is
considered.
• A detailed report outlining mitigation activities will be prepared and submitted to DEH.
Based on review of the reports, DEH concurs with the proposed Soil Reuse Plan. Activities
outside those implicitly proposed and approved herein or deviations from the
aforementioned workplan must be proposed in writing and approved by DEH prior to
implementation.
If you have any questions regarding this project, please do not hesitate to call me at (858) 505 -6863.
Sincerely,
Digitally zi,ed by Keith Kezer
DN cn =Keith Diego,
Keith
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ou= Department or Environrnental Health,
Kezer
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Date: 2013.04.0415:59:09 -0I'00'
KEITH E. KEZER, Project Manager
Site Assessment and Mitigation Program
cc: Ryan Marcos, SCS Engineers
Kevin Heaton
2012.04.0417:05:36
,.a,a - 07'00'
KEVIN M. HEATON, PG 4163, CHg 163
Senior Hydrogeologist
Site Assessment and Mitigation Program
H02358 -002 Soil Reuse Plan Approval Letter 3 -30 -2012