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Corrective Action Program: Working with Your Local Agency to Solve Local Problems James Clay County of San Diego Department of Environmental Health Site Assessment & Mitigation Program
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Corrective Action Program: Working with Your
Local Agency to Solve Local Problems
James ClayCounty 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 Application submission and acceptance was a multi-year process.
What is Corrective Action?
O Corrective Action is the term used in federal (RCRA) and state (HSC Ch. 6.5) law for the cleanup of hazardous waste or constituents at a facility engaged in the management of hazardous waste.
O Corrective Action is all the activities taken to investigate, characterize, evaluate, remove, or remediate a release of a hazardous waste or constituents to a level of human health and environmental protection compatible with the use of the property.
Corrective Action cont.
Corrective Action does not apply to:
1. The cleanup of waste residue during closure of a hazardous waste management unit
2. Small spills and releases that are cleaned up as part of routine housekeeping
3. Emergency response actions
Corrective Action Delegation to CUPA
O A two Tier delegation approach was adopted based on CUPA qualifications and the complexity of the site requiring corrective action.
O A qualified CUPA and DTSC are the only agencies authorized to implement the corrective action requirements of the Unified Program (HSC 25404.1).
CA Delegation cont.Tier 1 delegation authority allows a UPA to:
O Oversee Preliminary Endangerment Assessments
O Issue orders requiring corrective action at less complex sites
O Oversee corrective action at less complex sites
Less Complex SiteO Contaminants of Concern limited to
those for which cleanup screening numbers have been developed (CHHSLs)
O Cleanup will consist of removing less than 60 cubic yards of contaminated material
O Cleanup will achieve 10-6 risk screening levels for all contaminants
CA Delegation cont.
Tier 2 delegation authority allows a UPA to:
O Implement and enforce all Tier 1 activities
O Enforce corrective action at all facilities within the jurisdiction of the CUPA
O Oversee corrective action at complex sites
When is Corrective Action Required?
Corrective Action Required
Phase II Environmental
Assessment
InspectionsPBR/CA Closure
Suspected Release
No Further Investigation
Required Further Investigation
Required
Clean Closure
Title 22 CCR Section 68400.16
Requires a corrective action process that fulfills the following:
O Meaningful public involvementO Site screening using Preliminary
Endangerment Assessment (PEA) manualO Adequate site characterization of release
and risk assessment that evaluates riskO Cleanup that is protective of human health
and environment (10-6 risk level)
Title 22 CCR Section 68400.16 cont.
O Adequate oversight to ensure corrective action is completed appropriately
O Enforcement to ensure corrective action is performed
O Financial assurance for long term implementation of corrective action remedies
O Requirement for land use covenants for residual contamination left in place that is not suitable for unrestricted land use
Sources for Corrective Action Cases
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
O Analytical data submitted in compliance with Monitoring Well Program permits at sites that are were CUPA permitted facilities
Case StudySymcoat Metal Processing, Inc.
10840 Thornmint Road, San Diego, CA 92127
Symcoat Metal Processing, Inc.
O Sampling required in accordance with PBR closure plan requirements of Title 22 CCR 67450.3(c)(11)(B) for fixed treatment units
O Operated on property since 1992
O Conducted parts plating, anodizing and painting operations
Symcoat Metal Processing, Inc.
O Liquid waste stream was treated onsite under PBR guidance
O Waste stream processed by flocculation and precipitation which is then filter pressed into a solid filter cake
O Discharge of liquids under permit into San Diego County Publically Operated Treatment Works (POTW)
Symcoat Metal Processing, Inc.
O On April 10, 2014, DEH staff conducted a site inspection of the former Symcoat Metal Processing, Inc. facility.
O Based on the site inspection, DEH identified five areas of concern (AOCs) that may have had releases of hazardous waste or hazardous constituents into the environment.
Symcoat Metal Processing, Inc.
O AOC #1: Paint Storage AreaO AOC #2: Plating Lines O AOC #3: Waste Treatment Equipment
AreaO AOC #4: Dedicated Sewer Line Sampling
Port AreaO AOC #5: Chem Film Room
Plating Lines
Nickel Plating Line
Nickel Plating Line
Anodizing Line
Symcoat Metal Processing, Inc.
O 19 soil sample locations proposed. Samples to be collected by Geoprobe direct push drill rig.
O The samples will be collected with an Encore sampler from the retracted Geoprobe push sampler.
O Sample analysis will be for pH by EPA Method 9045, CAM 17 metals by EPA Method 6010B, and semi-volatile analysis for select samples by EPA method 8270
O Groundwater estimated to be >100 feet below ground surface
Symcoat Metal Processing, Inc.
O Symcoat’s December 16, 2005 Closure Plan proposed:
O Soil and/or groundwater sampling and, if necessary, remediation
O Sampling of the concrete in the upper inch of the containment areas and the analysis of the samples for metals.
O Sampling of areas where the concrete is visibly deteriorated or cracked, will be sampled and tested for contamination The proposal for the evaluation and sampling of the impacted areas of concrete will need to be addressed in the forthcoming PEA.
