Ewan Moffat County of San Diego Department of Environmental Health Site Assessment amp Mitigation Program Corrective Action Designation On February 28 2014 the Department of Toxic Substances Control DTSC delegated authority to DEH ID: 813151
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Slide1
Corrective
Action
Program
Ewan Moffat
County of San
Diego
Department of Environmental Health
Site
Assessment &
Mitigation Program
Slide2Corrective Action Designation
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.
Applies to releases of substances from CUPA permitted facilities.
Slide3SAM
Programs
Local Oversight Program (LOP)
Voluntary Assistance Program (VAP)
Corrective Action Program (CAP)
Slide4Corrective
Action (CA)
Corrective Action does not apply
to:
R
eleases from non-CUPA permitted sources
Small spills and releases that are cleaned up as part of routine housekeeping.
Slide5Sources of Corrective Action Cases
Analytical data submitted in compliance with Monitoring Well Program permits at sites that
are or
were CUPA permitted
facilities
Referrals from Hazardous Materials Division, including routine inspections and PBR/CA closures
Recalcitrant Voluntary Assistance Program cases that are or were CUPA permitted facilities
Slide6When is Corrective Action Required?
Corrective Action Required
Phase II Environmental Assessment
Inspections
PBR/CA Closure
Suspected Release
No Further Investigation Required
Further Investigation Required
Clean Closure
Slide7Corrective Action Process
Responsible Party (RP) fills out Corrective Action Consent Agreement
If RP won’t sign Consent Agreement, DEH will issue a Corrective Action Order
Deposit account is funded
RP sets up Financial Assurance
Slide8Title 22 CCR Section 68400.16
Requires a corrective action process that fulfills
the following:
Site
screening using Preliminary
Endangerment Assessment
(PEA)
manual
Adequate
site characterization of release
and risk
assessment that evaluates
riskCleanup that is protective of human health and environment (10-6 risk level)
Slide9Slide10Summary
CAP for past or present CUPA facilities with significant releases to the environment
Enforcement, if necessary,
to ensure corrective action is
performed
Similar to VAP goals (adequate cleanup to environment and no health risks to future and present occupants)
Slide11Case Study - Next Presentation
Kyocera America, Inc.
11620 Sorrento Valley Road,
San
Diego, CA
92121
Slide12Questions?
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
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