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HomeMy WebLinkAboutSDP 2023-0014; CARLSBAD VILLAGE MIXED-USE - SB 330; PHASE I ENVIRONMENTAL SITE ASSESSMENT - AUGUST 8, 2023; 2023-08-08 PHASE I ENVIRONMENTAL SITE ASSESSMENT Tooley Carlsbad 945-1065 Carlsbad Village Drive Carlsbad, California Prepared for: GRT Carlsbad Village, LLC 2001 Wilshire Boulevard, Suite 420 Santa Monica, California 90403 Prepared by: GSI ENVIRONMENTAL INC. 7595 Irvine Center Drive, Suite 250 Irvine, California 949.679.1070 www.gsienv.com GSI Job No: 5923 Issued: August 8, 2023 GSI Job No.: 5923 Issued: August 8, 2023 PHASE I ENVIRONMENTAL SITE ASSESSMENT Tooley Carlsbad Carlsbad, California Tooley Carlsbad 945-1065 Carlsbad Village Drive i Phase I Environmental Site Assessment Report TABLE OF CONTENTS FINDINGS, OPINIONS, AND CONCLUSIONS ........................................................................... 1 1.0 INTRODUCTION ................................................................................................................. 6 1.1 Purpose of the ESA ....................................................................................................... 6 1.2 Significant Assumptions ................................................................................................ 6 1.3 Limitations ..................................................................................................................... 6 1.4 Non-Scope Considerations ........................................................................................... 7 1.5 Report Viability .............................................................................................................. 7 1.6 User Reliance ............................................................................................................... 7 2.0 SITE DESCRIPTION ............................................................................................................ 7 2.1 Current and Past Site Use ............................................................................................. 8 2.2 Site Physical Description ............................................................................................... 8 2.3 Surrounding Properties ............................................................................................... 10 2.4 Geologic, Hydrogeologic, Hydrologic, and Topographic Conditions ............................ 10 3.0 SITE RECONNAISSANCE ................................................................................................ 11 4.0 HISTORICAL INFORMATION ........................................................................................... 15 5.0 DOCUMENTS AND INTERVIEWS .................................................................................... 18 5.1 Documents .................................................................................................................. 18 5.2 Interviews/Questionnaires ........................................................................................... 32 6.0 RECORDS REVIEW .......................................................................................................... 32 6.1 Regulatory Agency Records Review ........................................................................... 32 6.1.1 City of Carlsbad Building Department ................................................................ 32 6.1.2 RWQCB - San Diego/SWRCB Geotracker ......................................................... 33 6.1.3 San Diego County Hazardous Materials Management Division-Department of Environmental Health ................................................................. 34 6.1.4 San Diego Air Pollution Control District .............................................................. 36 6.1.5 DTSC San Diego ............................................................................................... 39 6.1.6 Office of the State Fire Marshal .......................................................................... 39 6.1.7 County Assessor’s Office ................................................................................... 39 6.1.8 DTSC Hazardous Waste Tracking System......................................................... 40 6.1.9 CalGEM ............................................................................................................. 42 6.2 Environmental Lien Search and Activity and Use Limitaions ....................................... 42 6.3 Regulatory Database Review ...................................................................................... 43 6.3.1 On-Site Database Information ............................................................................ 43 6.3.2 Off-Site Database Information ............................................................................ 43 7.0 SUMMARY OF FINDINGS ................................................................................................. 45 8.0 DATA GAPS OR FAILURES ............................................................................................. 48 GSI Job No.: 5923 Issued: August 8, 2023 PHASE I ENVIRONMENTAL SITE ASSESSMENT Tooley Carlsbad Carlsbad, California Tooley Carlsbad 945-1065 Carlsbad Village Drive ii Phase I Environmental Site Assessment Report 9.0 DELETIONS OR DEVIATIONS FROM THE ASTM STANDARD ...................................... 48 10.0 CERTIFICATION ............................................................................................................... 49 11.0 REFERENCES .................................................................................................................. 50 EXHIBITS Summary of Environmental Conditions ...................................................................................... 4 Phase I ESA Viability ................................................................................................................. 7 (ASTM E1527-21, Section 4.6) .................................................................................................. 7 Plate 1 - 2003 Waste Removal Form Identifying the Removal of 110 Pounds of Waste PCE from Carlsbad Village Cleaners ..................................................................12 Plate 2 - 2013 Documentation of Groundwater Monitoring Well Destruction (CRA, 2013; Appendix G).........................................................................................................14 Plate 3 - MW-9 and CP-2 Locations (Tetra Tech, 2012; Appendix G) .......................................19 Plate 4 - 2013 DEH Correspondence (Appendix G) ..................................................................20 Plate 5 - 2013 DEH Correspondence (Appendix G) ..................................................................21 Plate 6 - 2017 Sample Locations (Tetra Tech, 2017) ................................................................22 Plate 7 - Soil Vapor Analytical Results for VOCs .......................................................................23 Plate 8 - Soil Analytical Results for TPH....................................................................................24 Plate 9 - Groundwater Analytical Results for TPH .....................................................................24 Plate 10 - Soil Analytical Results for VOCs ...............................................................................26 Plate 11 - Soil Vapor Analytical Results for Benzene and PCE .................................................26 Plate 12 - Indoor Air Quality Data for Benzene and TCE (note that PCE is not reported) ........................................................................................................................26 Plate 13 - Salem Soil Vapor Sample Locations .........................................................................27 Plate 14 - Indoor Air Quality Data for Benzene, PCE, and TCE .................................................28 Plate 15 - Soil Vapor Analytical Results for VOCs in the Vicinity of the Drycleaner ...................29 Plate 16 - Case Closure Summary ............................................................................................31 Plate 17 - Authority to Construct Petroleum-based Dry Cleaning Equipment ............................33 Plate 18 - VAP Application Text ................................................................................................33 Plate 19 - Inspection Report Identifying PCE in 2001 ................................................................34 Plate 20 - Records for New Business Not Identifying PCE ........................................................35 Plate 21 - Drums Identified in 2014 ...........................................................................................35 Plate 22 - Hazardous Wastes Listed for Albertsons (now Smart and Final) in 2013 ..................36 Plate 23 - Active Dry Cleaning Permit .......................................................................................37 Plate 24 - Notice of Violation dated June 3, 2016 ......................................................................37 Plate 25 - Notice to Comply dated April 16, 2019 ......................................................................38 Plate 26 - Notice of Violation dated July 29, 2021 .....................................................................38 Plate 27 - Manifest Summary for Carlsbad Village Cleaners (2006-2022) .................................41 Plate 28 - Manifest Summary for Carlsbad Village Cleaners (1995-2003) .................................42 GSI Job No.: 5923 Issued: August 8, 2023 PHASE I ENVIRONMENTAL SITE ASSESSMENT Tooley Carlsbad Carlsbad, California Tooley Carlsbad 945-1065 Carlsbad Village Drive iii Phase I Environmental Site Assessment Report TABLE OF CONTENTS FIGURES Figure 1. Site Location Map Figure 2. Site Plan APPENDICES Appendix A. Regulatory Database Search Report and Physical Setting Report Appendix B. Site Photographs Appendix C. Sanborn Fire Insurance Maps Appendix D. Topographic Maps Appendix E. Aerial Photographs Appendix F. City Directories Appendix G. User-Supplied Documents Appendix H. Questionnaires Appendix I. Agency File Requests/Responses GSI Job No.: 5923 Issued: August 8, 2023 PHASE I ENVIRONMENTAL SITE ASSESSMENT Tooley Carlsbad Carlsbad, California Tooley Carlsbad 945-1065 Carlsbad Village Drive iv Phase I Environmental Site Assessment Report COMMON ACRONYMS µg/L Micrograms per Liter AAI All Appropriate Inquiries ACBM Asbestos-Containing Building Material ACM Asbestos-Containing Material AHERA Asbestos Hazard Emergency Response Act APCD Air Pollution Control District APN Assessor’s Parcel Number AQMD Air Quality Management District AST Aboveground Storage Tank ASTM American Society for Testing and Materials AUL Activity and Use Limitation bgs Below Ground Surface BCAT Basic Category Number BTEX Benzene, Toluene, Ethylbenzene and Xylenes CalGEM California Geologic Energy Management Division CCR California Code of Regulations CERCLA Comprehensive Environmental Response, Compensation, and Liability Act CERCLIS Comprehensive Environmental Response, Compensation, and Liability Information System CERS California Energy Reporting System COC Contaminant of Concern CREC Controlled Recognized Environmental Condition CUPA Certified Unified Program Agency CVCI Cleanup in Vulnerable Communities Initiative DOGGR Division of Oil, Gas, and Geothermal Resources DTSC Department of Toxic Substances Control EPA Environmental Protection Agency EDR Environmental Risk Information Service ESA Environmental Site Assessment GPR Ground-Penetrating Radar HAZNET Facility and Manifest Data HREC Historical Recognized Environmental Condition HVAC Heating, Ventilation, and Air Conditioning HWS Hazardous Waste Site LBP Lead-Based Paint LCP Lead Containing Paint LLP Landowner Liability Protection LQG Large Quantity Generator LUST Leaking Underground Storage Tank MCL Maximum Contaminant Level mg/kg Milligrams per Kilogram mg/L Milligrams per Liter GSI Job No.: 5923 Issued: August 8, 2023 PHASE I ENVIRONMENTAL SITE ASSESSMENT Tooley Carlsbad Carlsbad, California Tooley Carlsbad 945-1065 Carlsbad Village Drive v Phase I Environmental Site Assessment Report COMMON ACRONYMS (CONT.) MSDS Material Safety Data Sheet MSL mean sea level MTBE Methyl Tertiary Butyl Ether MW Mega Watt NAICS North American Industry Classification System NA Not Available ND None Detected NESHAP National Emission Standards for Hazardous Air Pollutants NFA No Further Action NOV Notice of Violation NPL National Priorities List NTC Notice to Comply O&M Operations and Maintenance OSHA Occupational Safety and Health Administration PCB Polychlorinated Biphenyl PCE Perchloroethylene, Tetrachloroethylene, Tetrachloroethene, PERC pCi/L Picocuries per Liter ppb Parts per Billion ppm Parts per Million PTO Permit to Operate RCRA Resource Conservation and Recovery Act REC Recognized Environmental Condition RP Responsible Party RWQCB Regional Water Quality Control Board SFIM Sanborn Fire Insurance Map SIC Standard Industrial Classification Code SLIC Spills, Leaks, Investigation, and Cleanup SPCC Spill Prevention and Countermeasure SQG Small Quantity Generator Stoddard In dry cleaning, Stoddard or 140-F are inexpensive combustible hydrocarbon mixtures that are similar to kerosene. SWRCB California State Water Resources Control Board SVOC Semi-Volatile Organic Compound TCE Trichloroethylene, Trichloroethene TDS Total Dissolved Solids TPH Total Petroleum Hydrocarbons TPHd Total Petroleum Hydrocarbons (diesel range) TPHg Total Petroleum Hydrocarbons (gasoline range) TPHo Total Petroleum Hydrocarbons (oil range) TRPH Total Recoverable Petroleum Hydrocarbons USDA United States Department of Agriculture USGS United States Geological Survey UST Underground Storage Tank VOC Volatile Organic Compound WDR Waste Discharge Requirement GSI Job No.: 5923 Issued: August 8, 2023 PHASE I ENVIRONMENTAL SITE ASSESSMENT Tooley Carlsbad Carlsbad, California Tooley Carlsbad 945-1065 Carlsbad Village Drive vi Phase I Environmental Site Assessment Report RELEVANT DEFINITIONS Recognized Environmental Conditions (RECs) RECs are defined in the ASTM Standard as “(1) the presence of hazardous substances or petroleum products in, on, or at the subject property due to a release to the environment; (2) the likely presence of hazardous substances or petroleum products in, on, or at the subject property due to a release or likely release to the environment; or (3) the presence of hazardous substances or petroleum products in, on, or at the subject property under conditions that pose a material threat of a future release to the environment. A de minimis condition is not a recognized environmental condition.” Controlled Recognized Environmental Conditions (CRECs) CRECs are defined in in the ASTM Standard as “recognized environmental condition affecting the subject property that has been addressed to the satisfaction of the applicable regulatory authority, or authorities with hazardous substances or petroleum products allowed to remain in place subject to the implementation of required controls. (for example, activity and use limitations or property use limitations).” Historical Recognized Environmental Conditions (HRECs) HRECs are defined in in the ASTM Standard as “a previous release of hazardous substances or petroleum products affecting the subject property and that has been addressed to the satisfaction of the applicable regulatory authority or authorities and meeting unrestricted use criteria established by the applicable regulatory authority or authorities without subjecting the subject property to any controls (for example, activity and use limitations, or other property use limitations).” 1 De minimis Conditions De minimis conditions are defined in in the ASTM Standard as: “a condition related to a release that generally does not present a threat to human health or the environment and that generally would not be the subject of an enforcement action if brought to the attention of appropriate governmental agencies. A condition determined to be a de minimis condition is not a recognized environmental condition nor a controlled recognized environmental condition.” 1 If the Site has received closure in the past, but a review of the closure information indicates that Site conditions do not meet unrestricted/residential land use standards, the Site is no longer considered an HREC, and must be identified as an REC. GSI Job No.: 5923 Issued: August 8, 2023 Tooley Carlsbad 945-1065 Carlsbad Village Drive 1 Phase I Environmental Site Assessment Report PHASE I ENVIRONMENTAL SITE ASSESSMENT Tooley Carlsbad Carlsbad, California FINDINGS, OPINIONS, AND CONCLUSIONS At the request of GRT Carlsbad Village, LLC (GRT), GSI Environmental Inc. (GSI) has performed a Phase I Environmental Site Assessment (ESA) in conformance with the scope and limitations of the ASTM International, Inc. Standard E 1527-21, Standard Practice for Environmental Site Assessments: Phase I Environmental Assessment Process (ASTM Standard) for the property identified below and in Figures 1 and 2. Any exceptions to, or deletions from, this practice are described in Section 8.0 of this report. SITE IDENTIFICATION Name: Tooley Carlsbad Address: 945-1065 Carlsbad Village Drive City: Carlsbad County: San Diego State: California Assessor Parcel Number(s) Pre 2020: 203-320-28, 203-320-29, 203-320-30 Assessor Parcel Number(s) After 2020: 203-320-53, 203-320-54, 203-320-55, 203-320-56 The purpose of the Phase I ESA was to identify Recognized Environmental Conditions (RECs) as defined in the ASTM Standard. It is our understanding that this Phase I ESA has been solicited as part of environmental due diligence activities in connection with the potential redevelopment of the Site to a mixed use commercial and multi-family residential project. This report presents the results of the Phase I ESA and is based on the following: • Review of prior Site reports provided to GSI; • Information obtained from owner and/or user interviews; • Identification of current and past conditions and uses of the Site and adjacent properties; • A review of federal, state, tribal, and local regulatory databases including, but not limited to, underground storage tanks (USTs), aboveground storage tanks (ASTs), known or suspected release cases, the storage of hazardous substances and disposal of hazardous wastes including petroleum products, and institutional and engineering controls; • A review of historical records, such as historical aerial photographs, fire insurance maps (Sanborn maps), historical city directories, and historical topographic maps; • A review of state and local agency records, including but not limited to state environmental agencies, Building Departments, Fire Departments, and Health Departments; • A review of the physical setting and Site reconnaissance; and • Site reconnaissance. GSI Job No.: 5923 Issued: August 8, 2023 Tooley Carlsbad 945-1065 Carlsbad Village Drive 2 Phase I Environmental Site Assessment Report Summary of Findings The Site was utilized for agricultural purposes prior to 1947 and at least one residence was present after that time. In the early 1950s the Site was vacant undeveloped land and by the early 1960’s the Site was developed with the current commercial retail center. A drycleaning business has been active at the on-Site address of 1005 Carlsbad Village Drive since approximately 1987. Records indicate that tetrachloroethene (PCE) was the cleaning solvent in use on-Site until 2003, when the current tenant took over drycleaning operations and switched from PCE to DF2000, an Exxon Mobil Chemical hydrocarbon cleaning solvent. Based on waste manifest documentation, the current tenant may have continued to use the chlorinated solvents PCE and trichloroethene (TCE) in spot cleaners for their drycleaning operations for some period of time. Waste manifests document the disposal of halogenated solvents between 1995 and 2003, and the disposal of PCE and TCE between the years of 2006 and 2022. All dry cleaning equipment and associated chemicals and wastes were removed from the tenant space on March 31, 2023 and starting April 1, 2023 the dry cleaning business is a drop-off location only with all cleaning occurring at an off-Site dry cleaning facility. In 2012, the Staff of the San Diego County Department of Environmental Health (DEH) documented a meeting with environmental consultants for the adjacent former Texaco Service station located at 1089 Carlsbad Village Drive and reported that investigations had identified that a diesel separate-phase hydrocarbon (SPH) plume identified beneath the Site did not originate from the former Texaco Service station. A subsequent 2012 addendum to this document concludes that the diesel plume beneath the Site originated on-Site in the vicinity of MW-9 and CPT-2 (Site parking lot) and has not migrated significantly since it was released. Based on this information, DEH provided closure for the former Texaco Service station (identified as “Carlsbad Gas & Propane, case No. T0607399182) in June 2013 and groundwater monitoring wells that had been placed on the subject Site were destroyed in 2013. In May 2013, DEH informed the Site Owners identified as “Glenn S and E Gloria Carroll Trust A & Glenn S and E Gloria Carroll Trust B” that “should land use change and/or redevelopment occur at your property, Assessor’s Parcel Number (APN) 203-320-29-00, DEH regulatory oversight regarding the SPH will be required.” A Phase I/II ESA was completed in 2017 by TetraTech and identified three issues of potential environmental concern: • Dry cleaner, Carlsbad Village Cleaners, located at 1005 Carlsbad Village Drive (Carlsbad Village Drive) - This facility was identified as a possible REC due to the historical use of drycleaning solvents. • Adjacent service station (current 7-Eleven and former Carlsbad Gas & Propane/Texaco) located at 1089 Carlsbad Village Drive with possible migration of contamination on the Site. It was identified that free product diesel found beneath the Site may have migrated from this facility. The free product beneath the Site identified by the prior consultant for the adjacent service stations closure was identified as a possible REC. • Historical on-Site farming operations were noted to have potentially impacted and/or contributed to the on-Site plume of free product diesel found beneath the Site. For the Phase II portion of the 2017 investigation, eight soil borings were advanced, and soil, groundwater, and soil vapor samples were collected. Soil and groundwater samples were analyzed for volatile organic compounds (VOCs) and total petroleum hydrocarbons (TPH). Soil vapor samples were analyzed for VOCs. PCE was detected at a low concentration in one soil GSI Job No.: 5923 Issued: August 8, 2023 Tooley Carlsbad 945-1065 Carlsbad Village Drive 3 Phase I Environmental Site Assessment Report sample from 5 feet below ground surface (bgs) collected outside the dry cleaner tenant space; however, was not detected in the 12-foot soil sample from the same location or from either of two soil samples (one from 5 and one from 10 to 15 feet bgs) from each of three additional exterior groundwater sampling locations. PCE was not detected in any of the four groundwater samples collected outside of the dry cleaner. PCE was detected at relatively low concentrations in soil vapor samples from two of four exterior locations around the dry cleaner space. Elevated concentrations of petroleum hydrocarbons were detected in three groundwater samples collected in the area of the identified on-Site free product plume. The 2017 Phase I/II report by TetraTech concluded that the VOCs in soil and soil vapor do not present a significant environmental concern or vapor intrusion risk. Based on the relatively low concentrations of chlorinated VOCs in soil, soil vapor and/or groundwater, it was concluded that the dry cleaner did not present a REC. However, concentrations of petroleum hydrocarbons were detected in soil in the area of the previously reported free product plume. The source of the hydrocarbons was undetermined but may be related to a historical release from a diesel underground storage tank (UST) associated with historical on-Site farming operations. The report concluded that this issue may present potential additional assessment and/or cleanup liability for the property owner. The Site entered into a Voluntary Assistance Program (VAP) in July 2017 and an SB 1248 Notification dated 19 July 2018 identifies DEH as the lead agency for the Site. In 2019, a closure request was submitted to DEH that summarized the findings of previous assessments and requested regulatory closure for the Site based on the low level detections of VOCs at the Site and the limited extent of petroleum hydrocarbons within a localized area of the parking lot. A subsequent email from DEH requested additional data. Since 2019, additional soil, groundwater and soil vapor investigation has been completed. Groundwater sampling identified concentrations of TPH; however, PCE and TCE were not detected in groundwater. Results of soil vapor sampling indicate that some concentrations of VOCs (benzene, bromodichloromethane, and PCE) exceeded residential and commercial soil vapor screening levels calculated using the default attenuation factor (0.03) recommended by DTSC and State Water Resources Control Board (SWRCB; DTSC/SWRQB, 2023).Based on data collected at the Site through July 2021, the Additional Site Assessment and Request for Regulatory Closure (Closure Report) prepared by Ramboll was submitted to DEH and recommended no further action. The DEH issued a “Concurrence Letter” on 7 October 2021 and agreed with the recommendation for “no further action,” noting that if the Site use changes in the future, additional sampling and / or evaluation may be necessary, and agency notification may be required with both the groundwater and indoor air conclusions. The DEH provided a second letter dated 25 October 2021, which included a 4-page Case Closure Summary, that stated the objectives established for the Site under the VAP have been met for commercial use. However, any future development of the property may require reassessment to determine if the activities could result in a risk to public health. This assessment has revealed no RECs, controlled RECs (CRECs), historical RECs (HRECs), or de minimis conditions in connection with the Site except for the two CRECS described below. GSI Job No.: 5923 Issued: August 8, 2023 Tooley Carlsbad 945-1065 Carlsbad Village Drive 4 Phase I Environmental Site Assessment Report Summary of Environmental Conditions de m i n i m u s * RE C * CR E C * HR E C * Description Explanation of Potential Environmental Condition ● Petroleum- impacted soil and groundwater below site Petroleum-impacted soil and groundwater are present beneath the Site in the center of the parking lot. Based on a review of the environmental investigation reports related to the Site, the DEH provided letters dated 7 October and 25 October 2021 stating that the objectives established for the Site under the VAP have been met for commercial use. However, if Site use changes, then additional sampling and/or evaluation may be necessary and agency notification may be required. Because DEH has concurred that no further action is necessary at this time under the institutional control that additional evaluation may be necessary if the Site use changes, the petroleum-impacted soil and groundwater beneath the Site is a CREC. ● Drycleaners Dry cleaning operations (either on-Site dry cleaning or “drop off” operations) have taken place at the address of 1005 since approximately 1987. Waste manifests document the disposal of halogenated solvents between 1995 and 2003 and the disposal of PCE and TCE between the years of 2006 and 2022. On March 31, 2023, all dry cleaning equipment and associated chemicals/wastes were removed from the Site and since April 1, 2023, the Site has been a drop-off location only. Relatively low concentrations of VOCs have been detected in soil vapor and indoor air during historical investigations, with indoor air concentrations being attributed to ambient sources. Based on a review of the environmental investigation reports related to the Site, the DEH provided letters dated 7 October and 25 October 2021 stating that the objectives established for the Site under the VAP have been met for commercial use. However, if Site use changes, then additional sampling and/or evaluation may be necessary and agency notification may be required. Because concentrations of VOCs in soil vapor exceed residential screening levels and the DEH has concurred that no further action is necessary at this time under the institutional control that additional evaluation may be necessary if the Site use changes, the impacts associated with the drycleaner is a CREC. *Environmental Conditions definitions available on page (v) Opinions and Conclusions GSI has evaluated the information collected during the course of this Phase I ESA. Based on the Findings above, we have developed the following opinions about how the findings impact the Site, and the proposed mixed use redevelopment. The petroleum-related impacts in groundwater appear to be localized in a relatively small area in the central portion of the Site in the parking lot. The TPH groundwater plume does not appear to have migrated significantly and some natural attenuation is expected. In letters dated 7 October and 25 October 2021, DEH concurs with this assessment and indicates that no further investigation is warranted unless Site use changes. Based on the results of investigation to date, GSI agrees that limited migration of the TPH groundwater plume appears to be occurring and the plume is expected to remain relatively stable under the current land use. However, if the Site use changes or if the property is redeveloped, additional evaluation of Site conditions and Site use plans may be required under DEH oversight. A drycleaning business has been active at the address of 1005 Carlsbad Village Drive from approximately 1987 to present. However, on March 31, 2023 all dry cleaning equipment and GSI Job No.: 5923 Issued: August 8, 2023 Tooley Carlsbad 945-1065 Carlsbad Village Drive 5 Phase I Environmental Site Assessment Report associated chemicals and wastes were removed from the tenant space. Since April 1, 2023 the dry cleaning business has been a drop-off location only with all cleaning occurring at an off-Site dry cleaning facility. The depth to water is reportedly about 12 feet bgs and residential properties are located within approximately 100 feet to the south of the dry cleaner. Based on investigations conducted between 2017 and 2021 (including the results of three indoor air sampling events conducted in 2020 and 2021), although VOCs in soil vapor are present above residential screening levels, there does not appear to be an unacceptable vapor intrusion risk under the current commercial property use. In letters dated 7 October and 25 October 2021, DEH concurs with this assessment and indicates that no further investigation is warranted unless Site use changes. It is GSI’s opinion that if the building is significantly remodeled or reconfigured to the extent that the changes would impact ventilation or penetrate the floor slab of the building, then additional evaluation of indoor air quality may be warranted. In addition, if the Site buildings are demolished and new buildings are constructed on the Site, evaluation of Site conditions and Site use plans may be required under DEH oversight. Since 2019, additional soil, groundwater and soil vapor investigation has been completed. Groundwater sampling identified concentrations of TPH; however, PCE and TCE were not detected in groundwater. Results of soil vapor sampling indicate that some concentrations of VOCs (benzene, bromodichloromethane, and PCE) exceeded residential and commercial soil vapor screening levels calculated using the default attenuation factor (0.03) recommended by DTSC and State Water Resources Control Board (SWRCB; DTSC/SWRQB, 2023). The presence of VOCs at concentrations exceeding default soil vapor screening levels can be addressed with a standard redevelopment project design feature that includes a vapor intrusion barrier system or other design features to address potential vapor intrusion, and plans to maintain/monitor these systems and/or features over the lifetime of the building. GSI has reviewed the proposed Site redevelopment plans, and we understand that the vapor intrusion barrier system will be included in the final design to address potential vapor intrusion risk. In addition, a standard Soil Management Plan (SMP), will be prepared to support earthwork activities associated with the demolition of existing Site features and redevelopment. The SMP project design feature will be provided to the contractor and construction subcontractors and will outline the environmental Site conditions and procedures for screening and managing soil, stormwater and groundwater during redevelopment. The environmental Site conditions are not considered a constraint to future Site development or use and can be addressed with incorporation of standard project design features and adherence to standard construction protocols and regulatory compliance requirements. We recommend providing written notification to DEH consistent with the agency’s standard regulatory oversight process once final building plans are completed and prior to the issuance of a grading or building permit and anticipate the standard project design features referenced above will be adequate to address the potential for vapor instruction risk for new residential/mixed use development at the Site.. GSI Job No.: 5923 Issued: August 8, 2023 Tooley Carlsbad 945-1065 Carlsbad Village Drive 6 Phase I Environmental Site Assessment Report PHASE I ENVIRONMENTAL SITE ASSESSMENT Tooley Carlsbad Carlsbad, California 1.0 INTRODUCTION This Phase I environmental site assessment (ESA) was conducted to fulfill ASTM International, Inc. (ASTM) Standard E1527-21, Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process (ASTM Standard) and the EPA Standards and Practices for All Appropriate Inquiries (40 CFR Part 312) for the property identified below (Site; Figures 1 and 2). SITE IDENTIFICATION Name: Tooley Carlsbad Address: 945-1065 Carlsbad Village Drive City: Carlsbad County: San Diego State: California Assessor Parcel Number(s) Pre 2020: 203-320-28, 203-320-29, 203-320-30 Assessor Parcel Number(s) After 2020: 203-320-53, 203-320-54, 203-320-55, 203-320-56 1.1 Purpose of the ESA The purpose of the ESA was to identify Recognized Environmental Conditions (RECs) as defined in the ASTM Standard. It is our understanding that this Phase I ESA has been solicited as part of environmental due diligence activities in connection with the redevelopment of the Site. 1.2 Significant Assumptions Poinsettia cleaners is identified in the 1065 tenant space in a 1995 city directory, however, the current owners of the cleaners and the property manager have no knowledge of a dry cleaner ever being present anywhere except the current 1005 location. GSI assumes that the listing of a cleaners in 1065 is an error, and the reference to Poinsettia Cleaners at the 1005 address in 1995 is either a typo from “1005” or the property manager indicates it may be referencing the coin- operated laundry location that was present at that time in the 1065 tenant space. San Diego County assessor’s office parcel numbers changed in 2020. It is assumed that the current 203-320-53 parcel is the same as the 203-320-29 parcel that is referenced in 2013 DEH correspondence. 1.3 Limitations GSI has completed this Phase I ESA in accordance with generally accepted environmental property assessment practices applicable at the time and location of the assessment. This Phase I ESA is not and should not be construed as a warranty or guarantee, expressed or implied, regarding the presence or absence of environmental contaminants that may affect the Site. All findings, opinions, and conclusions reported in this Phase I ESA are based on conditions and available information existing at the time of the assessment. No independent verification of the information provided to GSI was made. While GSI has no reason to doubt the accuracy of the information provided, this report is accurate and complete only to the extent that information provided to GSI was itself accurate and complete. Site conditions and regulations (local, state, GSI Job No.: 5923 Issued: August 8, 2023 Tooley Carlsbad 945-1065 Carlsbad Village Drive 7 Phase I Environmental Site Assessment Report tribal, and federal) can change over time. Therefore, changes in Site conditions, available information, and/or regulations may alter the findings, opinions, and conclusions of this Phase I ESA. 1.4 Non-Scope Considerations Non-scope considerations include environmental issues or conditions that may warrant additional assessment but are outside the scope of the ASTM Standard. Environmental issues that are considered non-scope considerations are summarized in the ASTM standard and include, but are not limited to; emerging contaminants, asbestos-containing building materials (ACBM) unrelated to releases into the environment, indoor air quality, lead-based paint, mold, and radon. GSI was not retained to evaluate non-scope considerations as part of this ESA. 1.5 Report Viability This Phase I ESA is viable if it is utilized within 1 year of the date of acquisition or intended transaction related to the Site provided that certain individual components (identified in the table below) have been completed within the previous 180 days (180 days before the origination of a loan or a transaction date, as applicable to the Site.). This Phase I ESA is viable for 1 year after the collection of the first component was completed. After 1 year, a new Phase I ESA must be completed and all components updated regardless of previous updates. For this report, the final date of viability will be January 31, 2024. Phase I ESA Viability (ASTM E1527-21, Section 4.6) Component Component Completion Date Phase 1 ESA Update Required (180 days) New Phase I ESA Required (365 days) Interviews 2/22/23 8/21/23 2/22/24 Records Review 1/31/23 7/30/23 1/31/24 Visual Inspection 2/14/23 8/13/23 2/14/24 Environmental Professional Declaration 8/8/23 4/8/23 8/8/24 *Environmental Cleanup Lien (User) User Performed 180 days from completion 365 days from completion *A search of recorded environmental cleanup liens is the responsibility of the User and requires an update after 180 days. 1.6 User Reliance This report and all related correspondence has been prepared exclusively for use by GRT and may not be relied upon by any other person or entity without the express written permission of GSI and GRT. Without express written permission of both GSI and GRT, no third parties shall have any rights of recourse or recovery under course of action against GSI, its officers, employees, subcontractors, vendors, or successors. 2.0 SITE DESCRIPTION GSI contracted with Environmental Data Resources (EDR) to compile a physical setting report (Appendix A) that was used in combination with information obtained during Site reconnaissance, historical document review, interviews with the Site owner representatives during GSI Job No.: 5923 Issued: August 8, 2023 Tooley Carlsbad 945-1065 Carlsbad Village Drive 8 Phase I Environmental Site Assessment Report reconnaissance, review of regulatory agency records, and review of prior Site reports provided to GSI (if applicable) to produce a description of the Site and its physical setting. 2.1 Current and Past Site Use The Site was utilized for agriculture until approximately 1952. Between the early 1950’s and early 1960’s the Site was undeveloped vacant land. The current strip mall or plaza configuration was completed in the mid-1960’s. Current use includes the businesses listed below. Address Suite Business Name Use 945 NA Texas Wine & Spirits Liquor store area, back stock room, and restroom. 955 NA Smart & Final Retail grocery store area, back stock room, and restrooms. 975 NA Denault’s Ace Hardware Retail hardware store area, back stock room, and restrooms. 1005 A Carlsbad French Pastry Café Vacant store front area, and back area, while tile flooring improves the entire interior portion of the suite. 1005 B MPower Pilates and Fitness Exercise Studio 1005 D Carlsbad Village Pharmacy Pharmacy store front area and restroom. 1005 F Vacant Vacant 1005 G Carlsbad Village Cleaners Store front area, drycleaning area and restroom. 1025 NA Vacant Vacant. Formerly Mikko Sushi Restaurant. 1055 NA Lucky Street Antiques Retail antique store area. 1065 A/B Community Resource Center Resale Store Retail thrift store area and restroom. 1065 C Carlsbad Village Coin Laundromat coin operated laundromat area, and restroom. 1065 D El Puerto Mexican & Seafood Restaurant, and restroom. 1065 F Golden Tee Cocktail Lounge Restaurant and restroom. 2.2 Site Physical Description The Site includes an asphalt parking lot and six separate buildings and one ATM kiosk as described in the tables below. SITE DETAILS Physical Description: The Site is a strip mall with six buildings and an ATM kiosk. Roads: The main entrance to the Site is located on the northern side of the Site and is accessible via Carlsbad Village Drive. Parking Facilities: Asphalt paved parking lot. Site Zoning: Commercial Vicinity Zoning: Commercial and Residential Site Size (acres): 4.12 acres Current Property Use: Village Plaza shopping center: six one-story buildings currently being utilized by several commercial operations, including a grocery store, thrift store, restaurants, liquor store, hardware store, bakery, pharmacy, and dry cleaner. Surface Drainage Direction: Variable GSI Job No.: 5923 Issued: August 8, 2023 Tooley Carlsbad 945-1065 Carlsbad Village Drive 9 Phase I Environmental Site Assessment Report BUILDING DESCRIPTION – Building 1 Building Age: Built between 1953 and 1964 Building Details One-story commercial building located along the northwestern corner of the property boundary Basements: None Building Square footage: 2,500 sq foot Building Occupants: Texas Wine and Spirits Building Operations: Liquor Store BUILDING DESCRIPTION – Building 2 Building Age: Built between 1953 and 1964 Building Details One-story commercial building located along the southwestern corner of the property boundary Basements: None Building Square footage: 27,600 sq foot Building Occupants: Smart and Final Building Operations: Grocery Store BUILDING DESCRIPTION – Building 3 Building Age: Built between 1953 and 1964 Building Details One-story commercial building separated into multiple respective units located along the southern portion of the property boundary. Basements: None Building Square footage: 21,825 sq foot Building Occupants: De Naults True Value Hardware #8, Carlsbad French Pastry Café, MPower Pilates and Fitness, vacant spot, Carlsbad Village Pharmacy, Carlsbad Village Cleaners Building Operations: Hardware store, bakery, pharmacy, Pilates studio, and dry cleaner Building Interior Hazardous Substance Use or Presence: Formerly used petroleum-based drycleaning solvents at Dry Cleaners. The dry cleaners is now a drop-off location only. BUILDING DESCRIPTION – Building 4 Building Age: Built between 1953 and 1964 Building Details One-story commercial building located along the southeastern corner of the property boundary. Basements: None Building Square footage: 3,500 sq foot Building Occupants: None Building Operations: Vacant BUILDING DESCRIPTION – Building 5 Building Age: Built between 1953 and 1964 Building Details One-story commercial building located along the eastern portion of the property boundary. Basements: None Building Square footage: 7,700 sq foot Building Occupants: Community Resource Center Resale Store, Carlsbad Village Coin Laundromat, El Puerto Mexican & Seafood, Golden Tee Cocktail Lounge Building Operations: Cocktail lounge, Mexican restaurant, Coin-Op laundry mat, pharmacy, and watch shop GSI Job No.: 5923 Issued: August 8, 2023 Tooley Carlsbad 945-1065 Carlsbad Village Drive 10 Phase I Environmental Site Assessment Report BUILDING DESCRIPTION – Building 6 Building Age: Built between 1953 and 1964 Building Details One-story commercial building located along the northeast corner of the property boundary. Basements: None Building Square footage: 2,700 sq foot Building Occupants: Vacant Building Operations: Formerly Mikko Sushi restaurant, closed on 12/4/21. BUILDING DESCRIPTION – Building 7 Building Age: Built between 1953 and 1964 Building Details One outdoor ATM kiosk located along the northern portion of the Site, located near the main entrance of the Site. Basements: None Building Square footage: NA Building Occupants: None Building Operations: ATM SITE UTILITIES Sewage: City of Carlsbad Electricity: San Diego Gas and Electric Potable Water: City of Carlsbad Gas: San Diego Gas and Electric 2.3 Surrounding Properties SURROUNDING PROPERTIES Direction Address and Use North: New Apartment/condominium structure with first floor commercial businesses East: I-5 Freeway South: Oak Avenue, Residential West: Jack in the Box, residential, community center Northwest: 7-Eleven gas station 2.4 Geologic, Hydrogeologic, Hydrologic, and Topographic Conditions According to Tetra Tech (2017), the following description for soils and geology in the vicinity of the Site is provided from an Updated Site Conceptual Model, Corrective Action Plan, and Request for Site Closure Report for the northeast adjacent property, located at 1089 Carlsbad Village Drive, conducted on February 20, 2013: Based on the geologic map of the northwestern portion of San Diego County, the Site is underlain by Quaternary-aged terrace deposits. The terrace deposits generally consist of reddish brown, poorly bedded, poorly- to moderately-indurated, sandstone, siltstone and conglomerate. Contacts of the Santiago Formation sandstone have been mapped in the vicinity of the Site and may underlie terrace deposits at depth. The Santiago Formation generally consists of light-colored, poorly-bedded, poorly-indurated, fine- to medium-grained sandstone interbedded with siltstone and claystone. The Santiago Formation is also known to have local coarse-grained sandstone and conglomerate deposits. Historical boring logs indicate that sand, silty sand, and sandy silt were encountered in the on- and off-Site borings. Soils underlying the Site were generally described as orangish-brown, to GSI Job No.: 5923 Issued: August 8, 2023 Tooley Carlsbad 945-1065 Carlsbad Village Drive 11 Phase I Environmental Site Assessment Report dark brown, fine- to medium-grained, moist, and loose to medium-dense sands with varying amounts of silt in the upper 15 to 25 fbg. Soils below that zone were generally described as gray to dark brown sand to sandy silt, saturated, very dense to hard, medium-grained, with trace cobbles. Blow counts and soil descriptions from the boring logs are consistent with the presence of terrace sediments in the upper 15 to 25 fbg. Borings that were drilled with a hollow-stem auger rig recorded blow counts of approximately 30 to 50 per foot in the upper stratigraphic zone, and significantly higher blow counts of approximately 100 blows per foot in the underlying lithology. This indicates that the deeper lithology is denser or more indurated and indicates the likely presence of bedrock beneath the overlying terrace sediments. The Site is located within the El Salto Hydrologic Subarea of the Buena Vista Creek Hydrologic Area in the Carlsbad Hydrologic Unit. Groundwater in the El Salto Hydrologic Subarea is designated as beneficial for municipal, and agricultural supply, and potentially beneficial for industrial supply. However, these beneficial uses do not apply west of the I-5 freeway where the Site is located. Groundwater in that portion of the El Salto Hydrologic Subarea is expected from the sources of drinking water policy. The closest surface water body to the Site is the Buena Vista Lagoon, which is approximately 0.6 mile to the northwest. The Buena Vista Lagoon is beneficial for contact and non-contact recreation, preservation of biological habitats of special significance, wildlife and marine habitat, rare, threatened or endangered species, and warm freshwater habitat. In addition, the Lagoon has the potential beneficial use of an estuarine habitat. Depth to groundwater beneath the Site has ranged historically from 10.50 feet in MW-3 on 4/26/2005 and 7/06/2005 to 14.76 in MW-8 on 1/06/2010, and groundwater elevations have ranged from 55.23 feet above msl in MW-9 on 6/26/2007 to o 62.00 feet above msl in MW-3 on 4/26/2005 and 7/06/2005. SITE DATA CURRENT AVAILABLE INFORMATION (with Source) Depth to Groundwater: 11 to 12 feet bgs (Tetra Tech, 2017) Closest Surface water: Buena Vista Lagoon (approximately 0.6 miles northwest) Groundwater Gradient: Southwest at a gradient of 0.03 ft/ft (Tetra Tech, 2017) 3.0 SITE RECONNAISSANCE A Site reconnaissance was performed on 14 February 2023 by Samantha Curtis of GSI to observe current Site conditions and identify and document potential notable environmental conditions. No property representatives were present during the Site reconnaissance. However, Ms. Curtis completed the previous Site reconnaissance included in the 2021 Phase I ESA and was familiar with the Site layout and operations. It was observed that the only significant change to the property was the closure of the Mikko Sushi restaurant. The building is currently closed and surrounded by green fencing. With reference to the drycleaning business located at 1005 Carlsbad Village Drive, Ms. Curtis was not able to interview anyone on the property. However, Mr. Andrew Cerrina, representative for the Site, indicated that dry cleaning machines would be removed from the space by March 31, 2023 and that on-Site dry cleaning will no longer be performed. During the 2021 Site reconnaissance, Mr. Choi, who operates the drycleaning business, noted that his business had been in operation since approximately 2003. The business currently has a Bowe Model M26 drycleaning machine that sits within a spill containment structure that has utilized DF2000 solvent in the drycleaning machine since 2003. DF2000 is a hydrocarbon-based fluid and is not known to contain PCE or TCE. During the 2021 interview, Mr. Choi was not aware of documentation of PCE or TCE wastes being removed from his facility and did not know why those chemicals were listed on the waste manifests originating from his waste. A waste manifest was identified in the GSI Job No.: 5923 Issued: August 8, 2023 Tooley Carlsbad 945-1065 Carlsbad Village Drive 12 Phase I Environmental Site Assessment Report records for Mr. Choi’s business that indicated that 110 pounds of waste PCE was removed from the property in October of 2003, which is approximately the time when Mr. Choi would have taken over the business. The document identifying the removal of PCE is included below in Plate 1 and also included in the Photographic Log in Appendix B. Mr. Choi did not have any additional information regarding the drycleaning business that existed at the same location prior to his tenancy. Plate 1 - 2003 Waste Removal Form Identifying the Removal of 110 Pounds of Waste PCE from Carlsbad Village Cleaners The Table below summarizes observations during the reconnaissance. Photographs taken during the Site reconnaissance are included in Appendix B. Observations of Site conditions that may indicate the likelihood of an REC in connection with the Site are discussed in the following Sections. If the observation is indicated with a “yes”, additional information related to that item is included below the table and in Section 7.0, Summary of Findings, if relevant to Site RECs. GSI Job No.: 5923 Issued: August 8, 2023 Tooley Carlsbad 945-1065 Carlsbad Village Drive 13 Phase I Environmental Site Assessment Report GENERAL OBSERVATIONS YES NO Hazardous Substances and Petroleum Products in Connection with Identified Uses X Storage Tanks (current or removed) X Wells (dry, irrigation, injection, monitoring, abandoned, etc.) X Drains, Sumps, Clarifiers X Odors X Pools of Liquid X Drums X Hazardous Substance and Petroleum Products Containers (Not Necessarily in Connection with Identified Uses) X Unidentified Substance Containers X Air Emissions X Equipment that may Contain PCBs X Soil Stockpiles X Pits, Ponds, or Lagoons (Site or adjoining) X Stained Soil or Pavement X Stressed Vegetation from Something other than Insufficient Water X Solid Waste, Construction Debris, Trash Mounds X Wastewater, Storm Water, Discharged Water X Septic Systems or Cesspools X Wells (dry, irrigation, injection, monitoring, abandoned, etc.) Wells were not identified during the Site reconnaissance. However, wells belonging to the adjacent Former Texaco (current 7-11) have been present at the Site and were abandoned in 2013 as documented by Conestoga-Rovers & Associates in their 60-Day Well Destruction Notification Off-Site Wells for the Former Texaco Service Station at 1089 Carlsbad Village Drive (Appendix G; Plate 2).2 Hazardous Substance and Petroleum Products Containers (Not Necessarily in Connection with Identified Uses) Petroleum products (DF 2000) utilized in dry cleaning operations are present at the Site. 2 https://geotracker.waterboards.ca.gov/profile_report?global_id=T10000007197 GSI Job No.: 5923 Issued: August 8, 2023 Tooley Carlsbad 945-1065 Carlsbad Village Drive 14 Phase I Environmental Site Assessment Report Plate 2 - 2013 Documentation of Groundwater Monitoring Well Destruction (CRA, 2013; Appendix G) Equipment that may Contain PCBs Based on the owners understanding, there are no transformers located on the Site that may contain PCBs (Appendix H). GSI Job No.: 5923 Issued: August 8, 2023 Tooley Carlsbad 945-1065 Carlsbad Village Drive 15 Phase I Environmental Site Assessment Report 4.0 HISTORICAL INFORMATION GSI contracted with EDR to compile historical documents for the Site and surrounding area to develop an understanding of the history of the Site. The following historical data sources were compiled and are included in the Appendices: • Sanborn fire insurance maps (Appendix C), • United States Geological Survey (USGS) topographic maps (Appendix D), • Aerial photographs (Appendix E), and • City directories (Appendix F) Pertinent historical information is incorporated in the Summary of Findings (Section 7.0). Historical Source Available Dates Sanborn Fire Insurance Maps (SFIM) SFIMs were available for the years 1929 and 1950. USGS Topographic Maps (USGS) USGS topographic maps were available for the years 1893, 1898, 1901, 1947, 1948, 1949, 1968, 1975, 1997, and 2012. Maps available between 1893 and 2012 are on a large scale and do not provide detail to decipher changes in the Site use. Aerial Photographs (AP) APs were available for the years 1939, 1946, 1953, 1964, 1967, 1970, 1979, 1985, 1990, 1994, 1997, 2002, 2005, 2009, 2012, 2016, and 2020 City Directories (CD) The Site was identified in City directories in 1991, 1995, 2000, 2006, and 2017. GSI Job No.: 5923 Issued: August 8, 2023 Tooley Carlsbad 945-1065 Carlsbad Village Drive 16 Phase I Environmental Site Assessment Report Historical Summary (SFIM, USGS, and AP) Year Source Site Description Adjacent Site Description 1929 SFIM The Site does not appear on this map. A church is labeled to the south of the Site. A few dwellings are located to the south and west of the Site. Properties to the north and east do not appear on this map. 1939 AP The Site appears to be undeveloped and utilized for agricultural purposes. The surrounding area appears to be utilized for agricultural purposes. A few structures are located surrounding the Site. 1946 AP A structure appears on the Site that may be residential. Most of the Site still appears to be vacant and used for agricultural purposes. The surrounding area has been developed with additional residential structures. 1950 SFIM The Site does not appear on this map. Properties to the north and east do not appear on this map. Additional dwellings are located to the south and west of the Site. 1953 AP No significant changes from the 1946 AP. The beginnings of freeway construction are identified to the east. Additional residential structures have been built to the north, south, and west. 1964 AP The Site appears to be completed as a strip mall. A gas station and residences appear to the north. To the northeast, across the San Diego Freeway, there is another gas station. The area to the south includes residences and a community center. 1967 AP A parking lot has been completed for the strip mall. No significant changes. 1970 AP No significant changes. No significant changes. 1979 AP No significant changes. A restaurant and hotel/motel have been built to the north. 1985 AP No significant changes. A new set of buildings have appeared to the north. 1990 AP No significant changes. No significant changes. 1994 AP No significant changes. No significant changes. 1997 AP No significant changes. No significant changes. 2002 AP No significant changes. No significant changes. 2005 AP No significant changes. No significant changes. 2009 AP No significant changes. A gas station has been removed to the north of the Site, across Carlsbad Village Drive. 2012 AP No significant changes. No significant changes. 2016 AP No significant changes. No significant changes. 2020 AP No significant changes. The land to the north of the Site, across Carlsbad Village Drive, appears to be graded for redevelopment. Historical City Directory Summary Site or Direction Address Directory Listing Site See table below. North 1089 Carlsbad Village Drive Carlsbad Texaco (1991-2004), Carlsbad Gas & Propane (2006-2014), 7-Eleven (2017) 1006 Carlsbad Village Drive Motel 6 (1994, 2006-2017), Terry Borkovetz (2004) GSI Job No.: 5923 Issued: August 8, 2023 Tooley Carlsbad 945-1065 Carlsbad Village Drive 17 Phase I Environmental Site Assessment Report Historical City Directory Summary Site or Direction Address Directory Listing East NA NA South 985 Oak Avenue Gerends Le Mrs (1965), Victor Vera (1970-1994, 2000-2006), Sherri Vista (1995), F Bloom (1999, 2009-2014) West 901 Carlsbad Village Drive Jack in the Box (1994-2017) Site Tenant Years Listed 945 Carlsbad Village Drive Texas Liquor Carlsbad 1994 2017 955 Carlsbad Village Drive Big Bear Super Markets 1994 1994 Carlsbad 1995 1995 ALBERTSONS FOOD CENTER 1999 2017 Smart & Final Extra 2017 2017 975 Carlsbad Village Drive North County Auto Parts 1995 1995 DENAULTS TRUE VALUE HARDWARE 2000 2017 985 Carlsbad Village Drive Photo Place 1994 2000 995 Carlsbad Village Drive Wells Fargo ATM 2017 2017 1005 Carlsbad Village Drive All Brite Janitorial Retail Supplies 1991 2017 Carlsbad Country Bakery & Dell 1991 1995 E L CAMIN O PHARMACY 1991 2014 El Camino Photography See Stephen Photography ..... 1991 1991 El Camino Pre School 1991 1991 Golden Crust Bakery See Carlsbad Country Bakery & Deli 1991 1991 All Brite Vacuum & Sewing Repair Center 1995 2014 Carlsbad Cake & Party Shop 1995 1995 Carlsbad Capital Group .......................... 1995 1995 Carlsbad Country Bakery 1995 1995 Carlsbad Rubber Stamp & Copy Center 1995 1995 Itclitol Statlons Carlsbad 1995 1995 A B C DISCOUNT WINDOW CARE 2000 2000 CARLSBD FRENCH PASTRIES CAFE 2000 2017 POINSETTIA CLEANERS 2000 2009 RUG DOCTOR RENTS 2000 2000 BERDUGO ENTERPRISES 2006 2009 CARLSBAD VILLAGE CLEANERS 2006 2017 NATTYS 99 CENT CITY 2006 2017 Carlsbad Village Pharmacy 2017 2017 1025 Carlsbad Village Drive CARLS BAD COVE 1991 1995 GSI Job No.: 5923 Issued: August 8, 2023 Tooley Carlsbad 945-1065 Carlsbad Village Drive 18 Phase I Environmental Site Assessment Report Site Tenant Years Listed MIKKO JAPANESE CUISINE 2000 2017 1065 Carlsbad Village Drive Giant New York Pizza Carlsbad 1991 2000 Golden Tee Cocktail Lounge 1991 2017 Poinsettia Barber Shop 1991 2017 Carlsbad Clock Shop 1991 2017 VILLAGE HAIRLINES 1991 2017 POINSETTIA CLEANERS (this is likely the laundromat) 1995 1995 BOBS GNYP & ITALIAN RESTAURANT 2000 2000 Hansen Vanlalmawi 2004 2017 EL PUERTO MEXICAN AND SEAFOOD 2006 2017 RED CARPET STYLING 2006 2006 5.0 DOCUMENTS AND INTERVIEWS The following owner and user provided documentation was utilized in this Phase I ESA. 5.1 Documents The following documents were provided for this Phase I ESA by GRT. All documents are included in Appendix G.3 1999 and 2000 Boring Logs (Included in the 2017 Phase I ESA by Tetra Tech) Boring logs were completed in 1999 by Pacific Environmental Group, in 2000-2001 by the IT Group, and in 2002-2003 by Northshore Engineering for the former Texaco station located at 1089 Carlsbad Village Drive. Groundwater monitoring wells MW-1 through MW-9 were installed to a total depth of approximately 25 feet. Cone penetrometer testing (CPT) was completed in 2008 by Gregg Drilling. 2012 DEH Correspondence (Included in the 2017 Phase I ESA by Tetra Tech) In 2012 the Staff of the DEH documented a meeting with Conestoga-Rovers & Associates (CRA) noting that CRA investigations had identified that diesel separate-phase hydrocarbon (SPH) identified beneath the Site did not originate at the former Texaco Service station located at 1089 Carlsbad Village Drive. DEH noted that CRA would provide an addendum to their 17 September 2012 report that includes a discussion of the SPH. The 17 September 2012 report by CRA was not available for GSI review. 2012 Addendum to Letter Regarding Origin of Diesel Separate-Phase Hydrocarbon Body – Conestoga-Rovers and Plume Models (Included in the 2017 Phase I ESA by Tetra Tech) This document provides a discussion that concludes that the diesel plume beneath the Site could not have originated at the former Texaco property located at 1089 Carlsbad Village Drive, but instead originated on-Site in the vicinity of MW-9 and CPT-2 and has not migrated significantly 3 If viewing the appendices digitally, each document can be found using Adobe bookmarks. GSI Job No.: 5923 Issued: August 8, 2023 Tooley Carlsbad 945-1065 Carlsbad Village Drive 19 Phase I Environmental Site Assessment Report since it was released. The locations of MW-9 and CP-2 are shown in the Plate 3 below and in Appendix G. Plate 3 - MW-9 and CP-2 Locations (Tetra Tech, 2012; Appendix G) 2013 DEH Letter to Glenn S and E Gloria Carroll Trust A & Glenn S and E Gloria Carroll Trust B (Included in the 2017 Phase I ESA by Tetra Tech) A letter from DEH dated 9 May 2013 to the Site owners references the results of the 2012 CRA investigation and notes that the CRA “study determined that the SPH beneath your property did not originate from the adjacent service station”…”CRA concluded that the SPH beneath your property originated in the vicinity of MW-9.” This letter states that any land use or redevelopment on the Site (APN 203-320-29-00) will require DEH regulatory oversight. A portion of this letter as well as a Figure identifying the location of MW-9 is included in the Plate 4 below, and the entire document is included in Appendix G. GSI Job No.: 5923 Issued: August 8, 2023 Tooley Carlsbad 945-1065 Carlsbad Village Drive 20 Phase I Environmental Site Assessment Report Plate 4 - 2013 DEH Correspondence (Appendix G) GSI Job No.: 5923 Issued: August 8, 2023 Tooley Carlsbad 945-1065 Carlsbad Village Drive 21 Phase I Environmental Site Assessment Report Plate 5 - 2013 DEH Correspondence (Appendix G) 2017 Phase I/II ESA – TetraTech A Phase I/II ESA was completed in 2017 (Tetra Tech, 2017) ESA at the Site in 2017 (Appendix G). Three issues of potential environmental concern were identified in the 2017 Phase I ESA: • Dry cleaner, Carlsbad Village Cleaners, located at 1005 Carlsbad Village Drive (Carlsbad Village Drive). This facility was identified as a possible REC due to the historical use of drycleaning solvents. • Adjacent service station (current 7-Eleven and former Carlsbad Gas & Propane/Texaco) located at 1089 Carlsbad Village Drive with possible migration of contamination on the Site. It was identified that free product diesel found beneath the Site may have migrated from this facility. The free product beneath the Site identified by the prior consultant for the adjacent service stations closure was identified as a possible REC. • Historical on-Site farming operations were noted to have potentially impacted and/or contributed to the on-Site plume of free product diesel found beneath the Site. The Phase II portion of the ESA was conducted to investigate the potential environmental concerns identified in the 2017 Phase I ESA. Eight soil borings were included in the investigation and soil, groundwater, and soil vapor samples were collected. The eight soil borings (TtSB-01 through TtSB-08) were advanced to a depth up to 15 feet below bgs. Four of the soil borings (TtSB-01 through TtSB-04) were converted into dual nested soil vapor probes (TtSV-1 through TtSV-4) with vapor probes installed at approximately 5 and 10 feet GSI Job No.: 5923 Issued: August 8, 2023 Tooley Carlsbad 945-1065 Carlsbad Village Drive 22 Phase I Environmental Site Assessment Report bgs. Grab groundwater samples were collected from seven of the eight borings advanced on Site (TtSB-01 through TtSB-05, TtSB-07, and TtSB-08). Soil and groundwater were analyzed for VOCs and TPH. Soil vapor was analyzed for VOCs. Sample locations are shown in Plate 6 below. Plate 6 - 2017 Sample Locations (Tetra Tech, 2017) Soil and Soil Vapor TPH was detected in soil within the previously identified plume and downgradient of the plume. Concentrations exceeding established USEPA Region 9 regional screening levels (RSLs) were identified at locations TtSB-7 and TtSB-8 at depths of 12.5 and 13 feet bgs. The sample depths were located directly above groundwater at the time of collection. VOCs in soil were not identified above RSLs in soil or soil vapor. As such, Tetra Tech did not consider the presence of the drycleaner a REC and did not consider the drycleaner a significant vapor intrusion risk or cleanup liability. Relevant groundwater and soil vapor analytical results are included in Plates 7, 8, and 9 below and can be found in Appendix G. GSI Job No.: 5923 Issued: August 8, 2023 Tooley Carlsbad 945-1065 Carlsbad Village Drive 23 Phase I Environmental Site Assessment Report Plate 7 - Soil Vapor Analytical Results for VOCs GSI Job No.: 5923 Issued: August 8, 2023 Tooley Carlsbad 945-1065 Carlsbad Village Drive 24 Phase I Environmental Site Assessment Report Plate 8 - Soil Analytical Results for TPH Plate 9 - Groundwater Analytical Results for TPH Groundwater TPH, VOCs and polyaromatic hydrocarbons (PAHs) were detected in groundwater samples in the vicinity of the TPH-impacted soils with naphthalene above the established RSL. Due to elevated GSI Job No.: 5923 Issued: August 8, 2023 Tooley Carlsbad 945-1065 Carlsbad Village Drive 25 Phase I Environmental Site Assessment Report naphthalene and TPH in groundwater, and PAHs that identified the source as a diesel or fuel oil, Tetra Tech identified the existing product plume area as an REC. 2018 SB 1248 Remedial Action Agreement On 19 July 2018 the DEH provided an SB 1248 notification indicating that the DEH would provide oversight for the Site. 2019 Ramboll Closure Request In April 2019, Ramboll prepared and submitted a Summary of Site Assessment and Request for Regulatory Closure letter report to the DEH. The report summarized the findings of previous assessments and requested regulatory closure for the Site, based on the low level detections of VOCs at the Site and the limited extent of petroleum hydrocarbons within a localized area of the parking lot. In a July 9, 2020 email from Mr. Ewan Moffett of the DEH, additional closure requirements were requested. As a follow up to these additional requirements, additional investigation was conducted by Dudek & Associates in November 2021. 2020 Salem Engineering Group Data Draft data tables obtained from the Salem Engineering Group identifies soil and soil vapor tables with a figure identifying sample locations (Plates 10 through 13). Concentrations of PCE in soil vapor were identified in the drycleaning tenant unit at maximum concentrations of 1,300 µg/mg3 at depths of 5 and 12 feet, exceeding the calculated screening level identified in the table below. Benzene was also detected in soil vapor at concentrations ranging to 18 µg/mg3 exceeding the calculated screening level identified in the table below. Benzene and TCE were identified in indoor air with benzene exceeding the SFRWQCB commercial screening value. No backup documentation was identified for the Salem data. GSI Job No.: 5923 Issued: August 8, 2023 Tooley Carlsbad 945-1065 Carlsbad Village Drive 26 Phase I Environmental Site Assessment Report Plate 10 - Soil Analytical Results for VOCs Soil Sampling Date Soil Sample Identification VOCs by EPA Method 8260B (µg/kg) 9/23/2020 DC-1 @5' ND (5.0) 9/23/2020 DC-1 @12' ND (5.0) 9/23/2020 DC-2 @5' ND (5.0) 9/23/2020 DC-2 @12' ND (5.0) 9/23/2020 DC-3 @5' ND (5.0) 9/23/2020 DC-3 @12' ND (5.0) Plate 11 - Soil Vapor Analytical Results for Benzene and PCE Date Sampled Sample Collection Point Benzene (µg/m3) PCE (µg/m3) 9/23/20 DC-1 @5' 5.4 850 9/23/20 DC-1 @5' REP 5.0 970 9/23/20 DC-1 @12' 19 460 9/23/20 DC-2 @5' 4.8 1,300 9/23/20 DC-2 @12' ND (3.2) 1,300 9/23/20 DC-3 @5' 9.1 810 9/23/20 DC-3 @12' 8.4 660 9/23/20 SV-1 @ 5 4.0 74 Calculated SL Residential SV 3.2 15.3 Calculated SL for Commercial SV 14 66.7 Plate 12 - Indoor Air Quality Data for Benzene and TCE (note that PCE is not reported) Date Sampled Sample Collection Point Benzene (µg/m3) TCE (µg/m3) 9/23/2020 IA-1 0.94 0.87 9/23/2020 IA-1 Dup 1.0 0.65 9/23/2020 OA-1 1.3 ND (0.55) CRWQCB-SF IA Residential ESL 0.097 0.48 CRWQCB-SF IA Commercial/Industrial ESL 0.42 3.0 GSI Job No.: 5923 Issued: August 8, 2023 Tooley Carlsbad 945-1065 Carlsbad Village Drive 27 Phase I Environmental Site Assessment Report Plate 13 - Salem Soil Vapor Sample Locations GSI Job No.: 5923 Issued: August 8, 2023 Tooley Carlsbad 945-1065 Carlsbad Village Drive 28 Phase I Environmental Site Assessment Report 2020 Dudek & Associates In November 2020, Dudek & Associates (Dudek) conducted groundwater and indoor air sampling at the Site. Only the analytical laboratory reports and tables were available for review. Five groundwater samples were collected and analyzed (B1-W through B5-W) for VOCs and TPH. No VOCs were detected in groundwater above laboratory reporting limits or Maximum Contaminant Levels (MCLs). TPH were detected at low concentrations above laboratory reporting limits. Four indoor air samples (IA-1 through IA-4) and one outdoor air sample (AA-1) were collected and analyzed for VOCs using USEPA method TO-15. Several VOCs were detected above laboratory reporting limits in one or more indoor or outdoor air sample collected during the November 2020 sampling event. All detections were below respective commercial screening criteria, with the exception of TCE and benzene. TCE was detected in all four indoor air samples at concentrations ranging from 0.46 µg/m3 to 3.5 µg/m3. TCE was not detected above laboratory reporting limits in the outdoor air sample. TCE was detected slightly above its applicable DTSC commercial screening level of 3 µg/m3 in one indoor sample within the Carlsbad Village Pharmacy Building Unit. Plate 14 - Indoor Air Quality Data for Benzene, PCE, and TCE Sample Location Description Sample Date Benzene (µg/mg3) PCE (µg/mg3) TCE (µg/mg3) IA-1 Dry Cleaner - Front of Tenant Unit 11/23/2020 1.4 0.20 0.82 IA-2 Dry Cleaner - Back of Tenant Unit 11/23/2020 1.5 <0.17 1.5 IA-3 Vacant Unit (former thrift store) - Center of Unit 11/23/2020 2.5 0.40 0.46 IA-4 Pharmacy - Front of Shop 11/23/2020 1.0 0.35 3.5 AA-1 Ambient Air - North of Dry Cleaner 11/23/2020 1.2 <0.17 <0.13 RWQCB Environmental SL for Residential Air 0.097 0.46 0.48 RWQCB Environmental SL for Commercial/Industrial Air 0.42 2.0 3.0 2021 GSI Soil Vapor Investigation In July 2021, soil vapor samples were collected at nine locations to further characterize the extent of PCE in soil vapor in the vicinity of the drycleaner (GSI, 2021; Plate 15). Soil vapor probes were installed at a depth of 5 feet bgs and samples were collected and analyzed for VOCs. Analytical results were evaluated by comparison to generic SLs for residential and commercial building (USEPA-AF SLs for current buildings and DTSC-AF SLs for future buildings). In each of the soil vapor samples collected, PCE was detected at concentrations exceeding the residential and commercial USEPA-AF SLs for current buildings (15 and 67 µg/m3, respectively), but below the commercial DTSC-AF SL for existing buildings (2,000 µg/m3). PCE was detected in soil vapor samples collected at seven locations at concentrations exceeding the residential DTSC-AF SL for future residential buildings (460 µg/m3). Benzene, bromodichloromethane, and chloroform were the only other VOCs detected at concentrations exceeding residential or commercial screening levels. These VOCS were detected GSI Job No.: 5923 Issued: August 8, 2023 Tooley Carlsbad 945-1065 Carlsbad Village Drive 29 Phase I Environmental Site Assessment Report at relatively low concentrations that are not uncommon for soil vapor samples collected in urban areas. Plate 15 - Soil Vapor Analytical Results for VOCs in the Vicinity of the Drycleaner 2021 Ramboll Additional Site Assessment and Request for Regulatory Closure The Additional Site Assessment and Request for Regulatory Closure letter to DEH dated 1 September 2021 was compiled by Ramboll Environment and Health (Ramboll) and included a summary of completed environmental investigations by Ramboll and others. With regard to the TPH plume located at the Site, Ramboll concludes that the petroleum-related impacts in groundwater appear to be localized in a small area in the central portion of the Site in the vicinity of the parking lot. The TPH groundwater plume does not appear to have migrated significantly and natural attenuation is expected. With regard to the drycleaning facility, Ramboll concludes that there exists no significant or widespread impacts to the subsurface and the Site does not represent a vapor intrusion risk under the current property use as VOCs were not detected in soil, soil vapor, or groundwater above the applicable screening criteria during several investigations conducted between 2017 and 2021; and significant vapor intrusion is not currently occurring based on the results of three separate indoor air sampling events conducted between 2020 and 2021. Ramboll concludes, “under the current commercial land use setting, no further investigation is warranted” and requests that case closure (e.g., no further action) is granted for the Site. In the GSI Job No.: 5923 Issued: August 8, 2023 Tooley Carlsbad 945-1065 Carlsbad Village Drive 30 Phase I Environmental Site Assessment Report event of future changes in Site use, Ramboll recommends conferring with DEH regarding any additional sampling and/or evaluation that might be necessary.” 2021 DEH VAP Review of the Additional Site Assessment A “Concurrence Letter” from the DEH dated 7 October 2021 summarized its review of Ramboll’s Additional Site Assessment and Request for Regulatory Closure Letter for the Site and concurred with Ramboll’s recommendation for no further action, noting that if the Site use changes in the future, additional sampling and / or evaluation may be necessary, and agency notification may be required with both the groundwater and indoor air conclusions. 2021 DEH Voluntary Assistance Program Case Closure The DEH provided a second letter dated 25 October 2021, which included a 4-page Case Closure Summary, that stated the objectives established for the Site under the VAP have been met for commercial use. However, any future development of the property may require reassessment to determine if the activities could result in a risk to public health. The Case Closure Summary is included below. Owner/User-supplied documents are included in Appendix G and have been incorporated in the Summary of Findings. GSI Job No.: 5923 Issued: August 8, 2023 Tooley Carlsbad 945-1065 Carlsbad Village Drive 31 Phase I Environmental Site Assessment Report Plate 16 - Case Closure Summary GSI Job No.: 5923 Issued: August 8, 2023 Tooley Carlsbad 945-1065 Carlsbad Village Drive 32 Phase I Environmental Site Assessment Report September 14, 2022 Conceptual Redevelopment Plan GSI has reviewed the proposed Site redevelopment plans. We understand that the project will be designed to include a vapor intrusion barrier system to address potential vapor intrusion risk. In addition, a standard SMP will be prepared to support earthwork activities associated with the demolition of existing Site features and redevelopment. The SMP will be provided to the contractor and construction subcontractors and will outline the environmental Site conditions and procedures for screening and managing soil, stormwater and groundwater during redevelopment. The environmental Site conditions are not considered a constraint to future Site development or use and can be addressed with incorporation of standard design features and adherence to standard construction protocols and regulatory compliance requirements. We recommend providing written notification to DEH consistent with the agency’s standard regulatory oversight process once final building plans are completed and prior to the issuance of a grading or building permit and anticipate the standard project design features referenced above will be adequate to address the potential for vapor instruction risk for new residentail/mixed use development at the Site. October 17, 2022 Microbial Clearance Inspection On October 13, 2022 a microbial clearance inspection was conducted at 1025 Carlsbad Village Drive, the former Mikko Sushi Restaurant. This document is further discussed in Section 6.1.4. October 19, 2022 Asbestos PCM Air Clearance & Visual Inspection On October 13, 2022 an asbestos PCM air clearance and visual inspection was conducted at 1025 Carlsbad Village Drive, the former Mikko Sushi Restaurant This document is further discussed in Section 6.1.4. 5.2 Interviews/Questionnaires In compliance with ASTM E1527-13, “User” and “Owner/Occupant” questionnaire was completed by Mr. Andrew Cerrina. Mr. Cerrina is not aware of any environmental issues related to the Site other than those summarized in the 2021 Phase I ESA and reiterated in this current Phase I ESA. 6.0 RECORDS REVIEW Environmental records were obtained by requesting records from state and local regulatory agencies and conducting a search of federal and state databases. 6.1 Regulatory Agency Records Review Regulatory agency records were requested on January 31, 2023. Agency requests included a request for reasonably ascertainable records for the Site addresses and APNs, as well as information related to nearby sites of potential concern. All agency file review requests and documents subsequently supplied by the agencies are included in Appendix K. 6.1.1 City of Carlsbad Building Department Records supplied by the building department include building permit applications, plumbing applications, sign permits, electrical permits and similar. Significant documents are summarized below. GSI Job No.: 5923 Issued: August 8, 2023 Tooley Carlsbad 945-1065 Carlsbad Village Drive 33 Phase I Environmental Site Assessment Report • A permit application was filed and approved in 2003 for the removal of PCE dry cleaning equipment and the installation of a petroleum-based dry cleaning machine at Poinsettia Cleaners. Authority to construct was granted on May 27, 2003 by the Air Pollution Control District (APCD) in San Diego County for “One (1) Columbia, Model TLHCS 400, 40-lb capacity, serial number to be determined closed-loop dry-to-dry cleaning machine equipped with cartridge filtration, built in refrigeration and solvent distillation systems and employing Exxon DF2000 solvent.” Plate 17 - Authority to Construct Petroleum-based Dry Cleaning Equipment 6.1.2 RWQCB - San Diego/SWRCB Geotracker The Carlsbad Village Plaza is included within the Geotracker on-line database with a case number of T100000011814 and is currently listed as “Completed – Case Closed as of 10/25/2021”.4 The documents included in the database include a Voluntary Assistance Program Application that includes a brief project description and type of assistance requested that references free product that was detected in soil below the parking lot. Plate 18 - VAP Application Text Responses from DTSC and RWQCB indicate that these two entities do not object to DEH providing oversight as the lead agency for the Site and a SB 1248 Notification dated 19 July 2018 identifies DEH as the lead agency for the Site. 4 https://geotracker.waterboards.ca.gov/profile_report?global_id=T10000011814 GSI Job No.: 5923 Issued: August 8, 2023 Tooley Carlsbad 945-1065 Carlsbad Village Drive 34 Phase I Environmental Site Assessment Report Additional documents included within the Geotracker online database are discussed in Section 5.1. 6.1.3 San Diego County Hazardous Materials Management Division-Department of Environmental Health Drycleaners – 1005 Carlsbad Village Drive Records obtained from DEH identified PCE at the Site in 2001. Mr. David Yoon is identified in inspection documents as the owner of the business since at least 1995 through 2003. The business is identified as Poinsettia Cleaners. Plate 19 - Inspection Report Identifying PCE in 2001 GSI Job No.: 5923 Issued: August 8, 2023 Tooley Carlsbad 945-1065 Carlsbad Village Drive 35 Phase I Environmental Site Assessment Report Records identify that the drycleaning business changed owners and name on 1 July 2003. PCE is not identified in the records for the new business. Plate 20 - Records for New Business Not Identifying PCE An inspection from 2014 identified the following drums located at the Site: Plate 21 - Drums Identified in 2014 During an inspection on September 24, 2021, Carlsbad Village Cleaners was reported to be a small quantity hazardous waste generator, generating less than 100 kilograms of hazardous waste per month. The facility was reported to store hazardous materials above reportable thresholds. Solvents, waste solvents, and waste still bottom filters were observed at the facility. The facility's EPA ID number (CAL000272302) was noted to be active/current at the time of inspection, hazardous waste manifests were available and reviewed for the past 3 years, hazardous waste labels were marked/readable, and hazardous waste containers were observed to be properly closed when not in use. Albertsons Records identified from Albertsons (currently Smart and Final) indicate that it was a small quantity generator (SQG) primarily due to returns and damaged goods as well as detergents and pharmaceuticals. In 2013 identify hazardous wastes disposed from the Site as the following: GSI Job No.: 5923 Issued: August 8, 2023 Tooley Carlsbad 945-1065 Carlsbad Village Drive 36 Phase I Environmental Site Assessment Report Plate 22 - Hazardous Wastes Listed for Albertsons (now Smart and Final) in 2013 6.1.4 San Diego Air Pollution Control District The San Diego Air Pollution Control District provided permit records, inspection reports, notices of violations, notices to comply, and a complaint investigation report for the Site. Significant documents are summarized below. A permit for a “petroleum-based dry cleaning operation consisting of one (1) closed loop dry-to-dry machine Bowe Model M26 (S/N: 115), capacity of 57 lbs” was issued to Carlsbad Village Cleaners on July 31, 2009. The permit status is active and expires on September 30, 2023. GSI Job No.: 5923 Issued: August 8, 2023 Tooley Carlsbad 945-1065 Carlsbad Village Drive 37 Phase I Environmental Site Assessment Report Plate 23 - Active Dry Cleaning Permit A Notice of Violation was issued on June 3, 2016 to Carlsbad Village Cleaners for altering the Columbia TLHCS 400 dry cleaning machine serial number 03A4199 and replacing it with Bowe M26 dry cleaning machine serial number 115 without obtaining written authorization from the Air Pollution Control Officer. Plate 24 - Notice of Violation dated June 3, 2016 GSI Job No.: 5923 Issued: August 8, 2023 Tooley Carlsbad 945-1065 Carlsbad Village Drive 38 Phase I Environmental Site Assessment Report A Notice to Comply was issued on April 16, 2019 to Carlsbad Village Cleaners for failing to have the material safety data sheet (MSDS) for "SGS HDS-A+ Hydrocarbon Soap" on-Site and readily available. Plate 25 - Notice to Comply dated April 16, 2019 A Notice of Violation was issued on July 29, 2021 to Carlsbad Village Cleaners for failing to maintain a log showing the date and pounds of materials cleaned in each load. Specifically, the Site did not record pounds of material processed from 06/01/21 to 07/28/21. Plate 26 - Notice of Violation dated July 29, 2021 GSI Job No.: 5923 Issued: August 8, 2023 Tooley Carlsbad 945-1065 Carlsbad Village Drive 39 Phase I Environmental Site Assessment Report On January 6, 2022 an anonymous complaint was filed with the San Diego APCD regarding debris from a fire at Mikko Sushi. The complainant stated that a contractor was hired for clean-up, but there was no containment for asbestos. The fire was reported to have begun in early December in a trash can which then ignited deep fryers in the kitchen. The inspector arrived at Mikko Sushi and observed the interior of the building to be completely burned. He reported some drywall debris on the interior of the building but did not observe debris outside the building. There were no signs of abatement/material disturbance during his investigation. He did not observe a violation of Rule 1206 or other APCD regulations. Based on documents provided by GRT, ECS Environmental, Inc (ECS) conducted a microbial clearance inspection and asbestos PCM air clearance inspection at the former Mikko Sushi restaurant on October 13, 2022. • The inspector noted that the affected drywall was removed, and no microbial growth or musky odors were detected at the facility. Three spore trap air samples were collected from within the east and west end of the restaurant as well as from the exterior of the building. Analytical results for the spore trap sample collected from within the west end of the building indicated the presence of wood-bourn fungus spores in the air. The cause of this was determined to be due to rotting wood framing. ECS recommended that a professional remediation company be hired to remove all affected rotting wood studs and rafters and that they be replaced with fresh lumber. Based on the interior spore counts, ECS concluded that the work area was clear for re-occupancy from an air quality standpoint. • As part of the Asbestos PCM Air Clearance, two air samples were collected within the west and east side of the vacant restaurant, after the removal of drywall/joint compound. Air sample results indicated that all samples passed asbestos PCM clearance criteria. No drywall/joint compound debris was found in the work area. The facility passed the visual clearance. 6.1.5 DTSC San Diego DTSC provided inspection reports, hazard appraisal and recognition plans, and insurance verification forms for the Site. Significant documents are summarized below. • A report submitted to the California Environmental Reporting System (CERS) in October 2020 determined Carlsbad Village Cleaners to be a hazardous waste generator. • A Hazard Appraisal and Recognition Plan-Pre Site Visit Form dated April 18, 2022, identified the following chemical hazard concerns at Carlsbad Village Cleaners: spent chlorinated solvents, spent flammable solvents, and used oil stored in 55-gallon metal/plastic drums. • During a transporter inspection on May 3, 2022, Carlsbad Village Cleaners was determined to be a dry cleaning business that does not transport hazardous waste. 6.1.6 Office of the State Fire Marshal In 2013 a natural gas leak was reported at 1065 Carlsbad Village Drive laundromat dryers. The incident was determined to not be an issue. 6.1.7 County Assessor’s Office In 2020 the County Assessor’s Office documented a change in the APN numbers for the Site. • 203-320-53 – 2.81 acres currently utilized for the buildings 945 through 1005 Carlsbad Village Drive and the primary parking lot. GSI Job No.: 5923 Issued: August 8, 2023 Tooley Carlsbad 945-1065 Carlsbad Village Drive 40 Phase I Environmental Site Assessment Report • 203-320-54- 0.40 acres currently utilized for parking. • 203-320-55- 0.39 acres currently utilized as a sushi restaurant. • 203-320-56- 0.52 acres currently utilized as a strip mall for the 1065 Carlsbad Village Drive units. 6.1.8 DTSC Hazardous Waste Tracking System The DTSC Hazardous Waste Tracking System (HWTS) was accessed on 16 February 2023. Waste manifests for Carlsbad Village Cleaners for Carlsbad Village Cleaners (also known as Poinsettia Cleaners) located at 1005 Carlsbad Village Road for the years 1995 to 2003 (CAD981629587)5 and the years 2006 to 2022 (CAL000272302)6, were identified as either “halogenated solvents”, “tetrachloroethylene” or “trichloroethylene” and the disposal volumes are identified in the tables below. 5 https://hwts.dtsc.ca.gov/facility/CAD981629587 6 https://hwts.dtsc.ca.gov/facility/CAL000272302 GSI Job No.: 5923 Issued: August 8, 2023 Tooley Carlsbad 945-1065 Carlsbad Village Drive 41 Phase I Environmental Site Assessment Report Plate 27 – Manifest Summary for Carlsbad Village Cleaners (2006-2022) Manifest Summary of PCE and TCE Disposal CAL000272302 – CARLSBAD VILLAGE CLEANERS DTSC Hazardous Waste Tracking System (HWTS). Report Generated: 2/16/2023 Ship Year Waste Description Waste Code Tons 2022 Tetrachloroethylene D039 0.1 2022 Trichloroethylene D040 0.13 2021 Tetrachloroethylene D039 0.1 2021 Trichloroethylene D040 0.1 2020 Tetrachloroethylene D039 0.1 2020 Trichloroethylene D040 0.1 2018 Tetrachloroethylene D039 0.07 2018 Trichloroethylene D040 0.07 2017 Tetrachloroethylene D039 0.1 2017 Trichloroethylene D040 0.1 2016 Tetrachloroethylene D039 0.12 2016 Trichloroethylene D040 0.12 2015 Tetrachloroethylene D039 0.12 2015 Trichloroethylene D040 0.12 2014 Tetrachloroethylene D039 0.1125 2014 Trichloroethylene D040 0.1125 2013 Tetrachloroethylene D039 0.11 2013 Trichloroethylene D040 0.11 2012 Tetrachloroethylene D039 0.12 2012 Trichloroethylene D040 0.12 2011 Tetrachloroethylene D039 0.12 2011 Trichloroethylene D040 0.12 2010 Tetrachloroethylene D039 0.2025 2010 Trichloroethylene D040 0.2025 2009 Tetrachloroethylene D039 0.3075 2009 Trichloroethylene D040 0.3075 2008 Tetrachloroethylene D039 0.39 2008 Trichloroethylene D040 0.39 2007 Tetrachloroethylene D039 0.195 2007 Trichloroethylene D040 0.195 2006 Tetrachloroethylene D039 0.195 GSI Job No.: 5923 Issued: August 8, 2023 Tooley Carlsbad 945-1065 Carlsbad Village Drive 42 Phase I Environmental Site Assessment Report Plate 28 – Manifest Summary for Carlsbad Village Cleaners (1995-2003) Manifest Summary of Halogenated Solvent Disposal CAD981629587 – CARLSBAD VILLAGE CLEANERS DTSC Hazardous Waste Tracking System (HWTS). Report Generated: 2/16/2023 Ship Year Waste Description Waste Code Tons 2003 LIQ W/ HALOG ORGANIC COMP>= 1000 MG/L 741 0.8 2003 Halogenated solvents F002 0.8 2002 LIQ W/ HALOG ORGANIC COMP>= 1000 MG/L 741 0.435 2001 LIQ W/ HALOG ORGANIC COMP>= 1000 MG/L 741 0.355 2001 Halogenated solvents F002 0.355 2000 LIQ W/ HALOG ORGANIC COMP>= 1000 MG/L 741 0.2775 2000 Halogenated solvents F002 0.2775 1999 HALOGENATED SOLVENTS 211 0.77805 1999 Halogenated solvents F002 0.77805 1998 HALOGENATED SOLVENTS 211 0.53399 1998 Halogenated solvents F002 0.53399 1997 HALOGENATED SOLVENTS 211 0.78639 1997 Halogenated solvents F002 0.78639 1996 HALOGENATED SOLVENTS 211 0.4214 1996 Halogenated solvents F002 0.4214 1995 HALOGENATED SOLVENTS 211 0.5048 1995 Halogenated solvents F002 0.5048 6.1.9 CalGEM The CalGEM online Well Finder mapping application interfaces with the online Well Statewide Tracking and Reporting System (WellSTAR) data base and is updated nightly.7 The Well Finder is used to find and locate oil and gas wells and other types of related facilities throughout the state. The Site is not within a mapped oil field and no oil wells appear to have been located on-Site or within the vicinity of the Site. 6.2 Environmental Lien Search and Activity and Use Limitaions GSI was not retained to perform a search for environmental liens and activity and use limitations (AULs) at the Site.8 Databases were searched by EDR that record information related to 7 https://www.conservation.ca.gov/calgem/Pages/WellFinder.aspx 8 AULs are defined in the ASTM Standard as legal or physical restrictions or limitations on the use of, or access to, a site or facility: (1) to reduce or eliminate potential exposure to hazardous substances or petroleum products in the soil, soil vapor, groundwater, and/or surface water on the property, or (2) to prevent activities that could interfere with the effectiveness of a response action, in order to ensure maintenance of a condition of no significant risk to public health or the environment. GSI Job No.: 5923 Issued: August 8, 2023 Tooley Carlsbad 945-1065 Carlsbad Village Drive 43 Phase I Environmental Site Assessment Report environmental liens and AULs and did not include any listings for the Site. The Site also is not on the online listing of deed restricted properties maintained by DTSC9 or SWRCB.10 6.3 Regulatory Database Review GSI contracted with EDR to compile a database report that summarizes the results of a search of federal, state, and tribal agency databases to assess whether the Site or nearby properties are under investigation for potential environmental issues or have been identified as conducting operations that could potentially impact the environment. The database report includes searches of regulatory databases of sites with environmental liens, deed restrictions, land use restrictions, engineering controls, and institutional controls.8 Significant findings from the database report are summarized below and in Section 7.0. The database report is included as Appendix H. 6.3.1 On-Site Database Information The following on-Site database information was available from EDR. Poinsettia Cleaners, Inc – 1005 Carlsbad Village Drive and 1005 G Elm Avenue, Carlsbad This portion of the Site is included in several databases and has been active at the address of 1005 Carlsbad Village Drive since approximately 1987. This address is currently occupied by Carlsbad Village Cleaners. Records indicate that tetrachloroethene (PCE) was the cleaning solvent in use on-Site until 2003, when the current tenant took over drycleaning operations and switched from PCE to DF2000, an Exxon Mobil Chemical hydrocarbon cleaning solvent. The current tenant, however, appears to have continued to use chlorinated solvents PCE and TCE in spot cleaners for their drycleaning operations for some period of time. Waste manifests document the disposal of halogenated solvents between 1995 and 2003, and the disposal of PCE and TCE between the years of 2006 and 2022. 6.3.2 Off-Site Database Information For the purposes of the assessment of the potential impact to the Site from nearby facilities identified in the database report, the local groundwater gradient is assumed to be to the southwest. Below is a discussion of facilities in close proximity to the Site that potentially contain subsurface impacts. 6.3.2.1 Nearby Gas Stations Several gas stations have been identified in the vicinity of the Site with documented Leaking Underground Storage Tanks (LUSTs). Based on documented remediation activities and site closure, these properties are not interpreted by GSI to represent a significant environmental concern to the Site. In addition, we understand that the proposed Site redevelopment project will be designed to include a vapor intrusion barrier system or other design features to address potential vapor intrusion associated with Site conditions. • 1089 Carlsbad Village Drive: Current 7-11, Former Carlsbad Texaco, Former Carlsbad Gas & Propane, Former Shell Oil Products. A second LUST listing for the site identified diesel, gasoline, Methyl Tertiary Butyl Ether (MTBE), TBA, and other fuel oxygenates in groundwater and soil, but was closed in 2010.11 Because this property is 9 https://www.envirostor.dtsc.ca.gov/public/deed_restrictions.asp 10 https://www.waterboards.ca.gov/water_issues/programs/deed_restrict/ 11 https://geotracker.waterboards.ca.gov/profile_report.asp?global_id=T0607399182 GSI Job No.: 5923 Issued: August 8, 2023 Tooley Carlsbad 945-1065 Carlsbad Village Drive 44 Phase I Environmental Site Assessment Report located immediately adjacent to the Site, it is discussed in more detail in the following section. • 1044 Carlsbad Village Drive: Chevron. This property was listed under several case numbers that were all closed between 1991 and 1995. The PCOC was listed as gasoline.12,13,14 • 920 Carlsbad Village Drive: High Desert Oil or Gasco. This property is listed as closed in 1998 with no listed PCOC.15 • 880 Carlsbad Village Drive: Former 76 Station 5723, Tosco Corp. This property is listed as closed in 1989 with the listed PCOC being diesel. A second LUST listing for the site identified diesel, gasoline, MTBE, TBA, and other fuel oxygenates in groundwater and soil, but was closed in 2010.16,17 • 1145 Carlsbad Village Drive: Carlsbad Shell. This property is listed as closed as of 1996 with the listed PCOC being gasoline.18 6.3.2.2 Current 7-11, Former Carlsbad Texaco, Former Carlsbad Gas & Propane, Former Shell Oil Products, 1089 Carlsbad Village Drive The adjacent property to the northeast is listed on the LUST database for leaking underground storage tanks associated with the service station that impacted “other groundwater (uses other than drinking water)” with gasoline, MTBE and other fuel oxygenates. This property was also listed as an historical automotive shop since the 1970’s. The LUST database includes the following case summary for this site: In April 1999, six soil borings (B-1 through B-6) were advanced by IT Corporation as part of a due diligence subsurface investigation. Soil samples and grab groundwater samples were collected and analyzed. Based on the laboratory results, DEH opened case H05780-001 on April 16, 1999. Overview of soil and groundwater impacts On March 31, 2000, a total of five USTs were removed; three 10,000-galllon gasoline, one 10,000-gallon diesel, and one 550-gallon waste oil. Soil samples were collected and analyzed under the direction of DEH. Based on laboratory results, impacted soil was excavated. Between March 2000 and November 2008, six soil borings (B-7 through B-12) were advanced, nine groundwater monitoring wells (MW-1 through MW-9) were installed, six hydropunch borings (HP-1 through HP-6) were advanced, and 11 cone penetration testing (CPT) borings (CPT-1 through CPT-11) were advanced. The analytical results from soil samples collected from the UST system removal/upgrade activities in 2000 and subsequent site assessment activities indicate that soil impacts are limited to the UST and dispenser areas. Based on groundwater monitoring and sampling events that occurred between May 2001 and January 2013, the groundwater flow direction is generally to the southwest at a gradient of approximately 0.03 foot per foot. The February 2013 groundwater monitoring report indicates that all petroleum and fuel oxygenate analytes are below maximum contaminant levels. The dissolved- phase contaminant plume is adequately defined. Free product (FP) was detected on the groundwater in only off site well MW-9, located in the adjacent parking lot. The isolated FP plume is located approximately 90 feet downgradient of the Sites USTs and is adequately defined. 12 https://geotracker.waterboards.ca.gov/profile_report.asp?global_id=T0608103750 13 https://geotracker.waterboards.ca.gov/profile_report.asp?global_id=T0608196199 14 https://geotracker.waterboards.ca.gov/profile_report.asp?global_id=T0608115847 15 https://geotracker.waterboards.ca.gov/profile_report.asp?global_id=T0607301478 16 https://geotracker.waterboards.ca.gov/profile_report.asp?global_id=T0607302933 17 https://geotracker.waterboards.ca.gov/profile_report.asp?global_id=T10000000288 18 https://geotracker.waterboards.ca.gov/profile_report.asp?global_id=T0607303180 GSI Job No.: 5923 Issued: August 8, 2023 Tooley Carlsbad 945-1065 Carlsbad Village Drive 45 Phase I Environmental Site Assessment Report Between April 2004 and February 2011, approximately 21.36 gallons of FP has been recovered by hand bailing and passive skimmer. The thickest FP measurement was reported at 2.12 feet. The last FP measurement was conducted on February 2, 2011, at a thickness of 0.08 feet. The consultant submitted a report arguing that the FP in the vicinity of off-site well MW-9 did not originate from the Site. DEH reviewed the report as well as Site data and determined that additional off site FP investigation is not required. DEH directed Shell to prepare and submit a Corrective Action Plan. It should be noted that FP remains beneath the adjacent property that is a parking lot of a shopping strip. Should land use change and/or redevelopment occur at the adjacent property (APN: 203-320-29-00), regulatory oversight regarding the FP is necessary. Overview of remediation: On April 3 & 4, 2000, approximately 254 cubic yards of impacted soil was excavated beneath the USTs and product piping and disposed off site. During the excavation activities, approximately 1,500 gallons of groundwater was pumped from the UST pit and treated off site. In February 2008, three groundwater extraction (GWE) events were conducted on off-site well MW-9 in an attempt to mitigate the FP. Approximately 866 gallons of groundwater/FP was extracted and treated off site. Based on the results of the GWE events, the consultant concluded that GWE remedial technology is not feasible for removing FP. Conclusions: Petroleum hydrocarbon contamination in soil and groundwater is adequately defined. The consultant estimates the volume of TPH-impacted soil greater than 100 Milligrams per Kilogram (mg/kg) remaining at the Site is approximately 337 cubic yards. The consultant also evaluated Site conditions based on the California State Water Resource Control Boards Low- Threat Closure Policy (LTCP). Based on their evaluation, the Site meets all necessary criteria under the LTCP. The consultant contacted the Carlsbad Municipal Water District (CMWD) and the DEH land Use Program (LUP) to confirm that there are no existing public water supply wells and no plans to install new water supply wells within a 1-mile radius of the Site. The DEH LUP indicated that there are two existing domestic wells located west-southwest of the Site approximately 2,900 feet. Based on the distance between the Site and the domestic wells, the consultant states that the domestic wells will not be impacted by residual contaminants from the Site. The residual soil and groundwater contamination will not impact human health, the environment, or nearby sensitive receptors. A Corrective Action Plan (CAP) dated February 20, 2013, was submitted to DEH. The CAP proposed No Further Action as the most feasible remedial alternative and requested closure of the case. Based on available data, DEH concurs with the consultants’ conclusions and approves closure of this case. Based on documented remediation activities and site closure, this property is not interpreted by GSI to represent a significant environmental concern to the Site. 7.0 SUMMARY OF FINDINGS The Site was utilized for agricultural purposes prior to 1947 and at least one residence was present after that time. In the early 1950s the Site was vacant undeveloped land and by the early 1960’s the Site was developed with the current commercial retail center. A drycleaning business has been active at the on-Site address of 1005 Carlsbad Village Drive since approximately 1987. Records indicate that tetrachloroethene (PCE) was the cleaning solvent in use on-Site until 2003, when the current tenant took over drycleaning operations and switched from PCE to DF2000, an Exxon Mobil Chemical hydrocarbon cleaning solvent. Based on waste manifest documentation, the current tenant may have continued to use the chlorinated solvents PCE and trichloroethene (TCE) in spot cleaners for their drycleaning operations for some period of time. Waste manifests document the disposal of halogenated solvents between 1995 GSI Job No.: 5923 Issued: August 8, 2023 Tooley Carlsbad 945-1065 Carlsbad Village Drive 46 Phase I Environmental Site Assessment Report and 2003, and the disposal of PCE and TCE between the years of 2006 and 2022. All dry cleaning equipment and associated chemicals and wastes were removed from the tenant space on March 31, 2023 and starting April 1, 2023 the dry cleaning business is a drop-off location only with all cleaning occurring at an off-Site dry cleaning facility. In 2012, the Staff of the San Diego County Department of Environmental Health (DEH) documented a meeting with environmental consultants for the adjacent former Texaco Service station located at 1089 Carlsbad Village Drive and reported that investigations had identified that a diesel separate-phase hydrocarbon (SPH) plume identified beneath the Site did not originate from the former Texaco Service station. A subsequent 2012 addendum to this document concludes that the diesel plume beneath the Site originated on-Site in the vicinity of MW-9 and CPT-2 (Site parking lot) and has not migrated significantly since it was released. Based on this information, DEH provided closure for the former Texaco Service station (identified as “Carlsbad Gas & Propane, case No. T0607399182) in June 2013 and groundwater monitoring wells that had been placed on the subject Site were destroyed in 2013. In May 2013, DEH informed the Site Owners identified as “Glenn S and E Gloria Carroll Trust A & Glenn S and E Gloria Carroll Trust B” that “should land use change and/or redevelopment occur at your property, Assessor’s Parcel Number (APN) 203-320-29-00, DEH regulatory oversight regarding the SPH will be required.” A Phase I/II ESA was completed in 2017 by TetraTech and identified three issues of potential environmental concern: • Dry cleaner, Carlsbad Village Cleaners, located at 1005 Carlsbad Village Drive (Carlsbad Village Drive) – This facility was identified as a possible REC due to the historical use of drycleaning solvents. • Adjacent service station (current 7-Eleven and former Carlsbad Gas & Propane/Texaco) located at 1089 Carlsbad Village Drive with possible migration of contamination on the Site. It was identified that free product diesel found beneath the Site may have migrated from this facility. The free product beneath the Site identified by the prior consultant for the adjacent service stations closure was identified as a possible REC. • Historical on-Site farming operations were noted to have potentially impacted and/or contributed to the on-Site plume of free product diesel found beneath the Site. For the Phase II portion of the 2017 investigation, eight soil borings were advanced, and soil, groundwater, and soil vapor samples were collected. Soil and groundwater samples were analyzed for volatile organic compounds (VOCs) and total petroleum hydrocarbons (TPH). Soil vapor samples were analyzed for VOCs. PCE was detected at a low concentration in one soil sample from 5 feet below ground surface (bgs) collected outside the dry cleaner tenant space; however, was not detected in the 12-foot soil sample from the same location or from either of two soil samples (one from 5 and one from 10 to 15 feet bgs) from each of three additional exterior groundwater sampling locations. PCE was not detected in any of the four groundwater samples collected outside of the dry cleaner. PCE was detected at relatively low concentrations in soil vapor samples from two of four exterior locations around the dry cleaner space. Elevated concentrations of petroleum hydrocarbons were detected in three groundwater samples collected in the area of the identified on-Site free product plume. The 2017 Phase I/II report by TetraTech concluded that the VOCs in soil and soil vapor do not present a significant environmental concern or vapor intrusion risk. Based on the relatively low concentrations of chlorinated VOCs in soil, soil vapor and/or groundwater, it was concluded that the dry cleaner did not present a REC. However, concentrations of petroleum hydrocarbons were detected in soil in the area of the previously GSI Job No.: 5923 Issued: August 8, 2023 Tooley Carlsbad 945-1065 Carlsbad Village Drive 47 Phase I Environmental Site Assessment Report reported free product plume. The source of the hydrocarbons was undetermined but may be related to a historical release from a diesel underground storage tank (UST) associated with historical on-Site farming operations. The report concluded that this issue may present potential additional assessment and/or cleanup liability for the property owner. The Site entered into a Voluntary Assistance Program (VAP) in July 2017 and an SB 1248 Notification dated 19 July 2018 identifies DEH as the lead agency for the Site. In 2019, a closure request was submitted to DEH that summarized the findings of previous assessments and requested regulatory closure for the Site based on the low level detections of VOCs at the Site and the limited extent of petroleum hydrocarbons within a localized area of the parking lot. A subsequent email from DEH requested additional data. Since 2019, additional soil, groundwater and soil vapor investigation has been completed. Groundwater sampling identified concentrations of TPH; however, PCE and TCE were not detected in groundwater. Results of soil vapor sampling indicate that some concentrations of VOCs (benzene, bromodichloromethane, and PCE) exceeded residential and commercial soil vapor screening levels calculated using the default attenuation factor (0.03) recommended by DTSC and State Water Resources Control Board (SWRCB; DTSC/SWRQB, 2023).Based on data collected at the Site through July 2021, the Additional Site Assessment and Request for Regulatory Closure (Closure Report) prepared by Ramboll was submitted to DEH and recommended no further action. The DEH issued a “Concurrence Letter” on 7 October 2021 and agreed with the recommendation for “no further action,” noting that if the Site use changes in the future, additional sampling and / or evaluation may be necessary, and agency notification may be required with both the groundwater and indoor air conclusions. The DEH provided a second letter dated 25 October 2021, which included a 4-page Case Closure Summary, that stated the objectives established for the Site under the VAP have been met for commercial use. However, any future development of the property may require reassessment to determine if the activities could result in a risk to public health. GSI has evaluated the information collected during the course of this Phase I ESA. Based on the Findings above, this assessment has revealed two CRECs in connection with the Site. • Petroleum-impacted soil and groundwater are present beneath the Site in the center of the parking lot. Based on a review of the environmental investigation reports related to the Site, the DEH provided letters dated 7 October and 25 October 2021 stating that the objectives established for the Site under the VAP have been met for commercial use. However, if Site use changes, then additional sampling and/or evaluation may be necessary and agency notification may be required as part of a standard regulatory oversight process. Because DEH has concurred that no further action is necessary at this time under the institutional control that additional evaluation may be necessary if the Site use changes, the petroleum-impacted soil and groundwater beneath the Site is a CREC. • Dry cleaning operations (either on-Site dry cleaning or “drop off” operations) have taken place at the address of 1005 since approximately 1987. Waste manifests document the disposal of halogenated solvents between 1995 and 2003 and the disposal of PCE and TCE between the years of 2006 and 2022. On March 31, 2023, all dry cleaning equipment and associated chemicals/wastes were removed from the Site and since April 1, 2023, the Site has been a drop-off location only. Relatively low concentrations of VOCs have been detected in soil vapor and indoor air during historical investigations, with indoor air concentrations being attributed to ambient sources. Based on a review of the GSI Job No.: 5923 Issued: August 8, 2023 Tooley Carlsbad 945-1065 Carlsbad Village Drive 48 Phase I Environmental Site Assessment Report environmental investigation reports related to the Site, the DEH provided letters dated 7 October and 25 October 2021 stating that the objectives established for the Site under the VAP have been met for commercial use. However, if Site use changes, then additional sampling and/or evaluation may be necessary and agency notification may be required as part of a standard regulatory oversight process. Because concentrations of VOCs in soil vapor exceed residential screening levels and the DEH has concurred that no further action is necessary at this time under the institutional control that additional evaluation may be necessary if the Site use changes, the impacts associated with the drycleaner is a CREC. If the Site buildings are demolished and new buildings are constructed on the Site, evaluation of Site conditions and Site use plans may be required under standard DEH regulatory oversight. Since 2019, additional soil, groundwater and soil vapor investigation has been completed. Groundwater sampling identified concentrations of TPH; however, PCE and TCE were not detected in groundwater. Results of soil vapor sampling indicate that some concentrations of VOCs (benzene, bromodichloromethane, and PCE) exceeded residential and commercial soil vapor screening levels calculated using the default attenuation factor (0.03) recommended by DTSC and State Water Resources Control Board (SWRCB; DTSC/SWRQB, 2023). The presence of VOCs at concentrations exceeding default soil vapor screening levels is addressed with the proposed redevelopment design that includes a vapor intrusion barrier system or other project design features to address potential vapor intrusion, and plans to maintain/monitor these systems and/or features over the lifetime of the building. GSI has reviewed the proposed Site redevelopment plans, and we understand that the vapor intrusion barrier system is included in the proposed project design to address potential vapor intrusion risk. In addition, a standard Soil Management Plan (SMP) will be prepared to support earthwork activities associated with the demolition of existing Site features and redevelopment. The SMP project design feature will be provided to the contractor and construction subcontractors and will outline the environmental Site conditions and procedures for screening and managing soil, stormwater and groundwater during redevelopment. The environmental Site conditions are not considered a constraint to future Site development or use and can be addressed with incorporation standard project design features and adherence to standard construction protocols and regulatory compliance requirements. We recommend providing written notification to DEH consistent with the agency’s standard regulatory oversight process once final building plans are completed and prior to issuance of a grading or building permit and anticipate the standard project design features referenced above will be adequate to address the potential for vapor intrusion risk for new residential/mixed use development at the Site. 8.0 DATA GAPS OR FAILURES Standard ASTM E1237-21 defines a “data gap” as a lack of or inability to obtain information required by the Standard despite good faith efforts by the environmental professional to gather such information. Significant data gaps are identified as those which affected the ability to identify RECs. A “data failure” is a type of data gap and is considered a failure to achieve the historical research objective even after reviewing reasonably ascertainable standard historical resources. This Phase I ESA has revealed no significant data gaps or data failures. 9.0 DELETIONS OR DEVIATIONS FROM THE ASTM STANDARD GSI Job No.: 5923 Issued: August 8, 2023 Tooley Carlsbad 945-1065 Carlsbad Village Drive 49 Phase I Environmental Site Assessment Report There were no deletions or deviations from ASTM Practice E-1527-21 in conducting this Phase I Environmental Site Assessment. 10.0 CERTIFICATION The Site is defined as the following: SITE IDENTIFICATION Name: 945-1065 Carlsbad Village Drive Address: 945-1065 Carlsbad Village Drive City: Carlsbad County: San Diego State: California APN(s) Pre 2020: 203-320-28, 203-320-29, 203-320-30 APN(s) After 2020: 203-320-53, 203-320-54, 203-320-55, 203-320-56 This environmental review of the Site as defined above was conducted by GSI on behalf of GRT. The review conducted by GSI meets or exceeds the requirements for a Phase I ESA specified in the ASTM Standard. We declare that, to the best of our professional knowledge and belief, we meet the definition of Environmental Professional as defined in §312.10 of 40 CFR 312. We have the specific qualifications based on education, training, and experience to assess the nature, history, and setting of the subject property. We have developed and performed all the appropriate inquiries in conformance with the standards and practices set forth in 40 CFR Part 312. Timothy F. Wood, PG, CHG Samantha Curtis, PG Principal Geologist Senior Geologist August 8, 2023 August 8, 2023 GSI Job No.: 5923 Issued: August 8, 2023 Tooley Carlsbad 945-1065 Carlsbad Village Drive 50 Phase I Environmental Site Assessment Report 11.0 REFERENCES ASTM E1527-21, Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process. ASTM E1527-13, Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process. Department of Toxic Substances Control (DTSC) and State Water Resources Control Board (SWRCB), 2023. Supplemental Guidance: Screening and Evaluating Vapor Intrusion, Final Draft, California Environmental Protection Agency, February. Environmental Data Resources (EDR), 2023, Database Reports for 945-1065 Carlsbad village Drive, January 31. a. Physical Setting Report b. Historical Aerial Photographs c. Historical Sanborn Fire Insurance Map Research Results d. Historical United States Geological Survey Topographic Map Results e. Historical Directory Report County of San Diego Department of Environmental Health, Land and Water Quality Division (DEH), 2013. DEH, 2018, DEH Requirement for Regulatory Oversight, Carlsbad Village Plaza, 945 Carlsbad Village Drive, Carlsbad, California, May 9. DEH, 2021, Voluntary Assistance Program (VAP) Base DEH 2018-LSAM-000500 – Review of Additional Site Assessment and Concurrence of No Further Action, Carlsbad Village Plaza, 945 Carlsbad Village Drive, Carlsbad, California, October 7. DEH, 2021, Voluntary Assistance Program (VAP) Base DEH 2018-LSAM-000500 – Objectives Met, Carlsbad Village Plaza, 945 Carlsbad Village Drive, Carlsbad, California, October 25. GSI Environmental (GSI), 2021, Soil Vapor Sampling Report, 1005 Carlsbad Village Cleaners, 945-1065 Carlsbad Village Drive, Carlsbad, California, November 19. Ramboll, 2021, Additional Site Assessment and Request for Regulatory Closure, Carlsbad Village Plaza, 945 Carlsbad Village Drive, Carlsbad, California, September 1. TRC, 2010, Quarterly Monitoring Report, Former 76 Station 5723, 880 Carlsbad Village Drive, Carlsbad, California, October through December 2009, January 13. Common References DWR, 1980, Bulletin 118-90, Groundwater Basins in California, January. California Department of Water Resources (DWR), 1961, Bulletin No. 104, Planed Utilization of the Ground Water Basins of the Coastal Plain of Los Angeles County, Appendix A Groundwater Geology, June. Online Resources California SWRCB Sites with Deed Restrictions - https://www.waterboards.ca.gov/water_issues/programs/deed_restrict/ California DTSC Land Use Restrictions - https://dtsc.ca.gov/land-use-restriction-sites/ California DTSC Envirostor website - https://www.envirostor.dtsc.ca.gov/public/ California SWRCB GeoTracker website - https://geotracker.waterboards.ca.gov/ California Geologic Energy Management Division - https://www.conservation.ca.gov/calgem GSI Job No.: 5923 PHASE I ENVIRONMENTAL SITE ASSESSMENT Tooley Carlsbad Carlsbad, California Tooley Carlsbad 945-1065 Carlsbad Village Drive, Carlsbad, California Phase I Site Assessment Report FIGURES Figure 1. Site Location Map Figure 2. Site Plan 0 0.75 1.5 Miles FIGURE 1 5923 TC_SiteLo cMap 20-Feb-2023 AV SITE LOCATION MAP 945 – 1065 Carlsb ad Village Drive,Carlsb ad, Califo rnia GSI Jo b No . Issued: Revised: Map ID: Drawn b y: Chk'd b y: Ap rv'd b y: £ Reference map p ro vided b y Esri, 2021. SITELOCATION ^_ ^_ Califo rniaCalifo rnia SC Drawn By: Chk'd By: Appv'd By:Map ID: Issued: GSI Job No. FIGURE 2 SITE MAP 5923 AV 14-Jul-2021 SC 945-1065 Carlsbad Village Drive, Carlsbad, California TC_SiteMap Projected Coordinate SystemDatum: NAD 83State Plane California Zone VIUnits: Feet07035 Feet q LEGEND 1) Aerial imagery provided by Microsoft Bing Maps, June 2020. 2) Reference map from "Tetra Tech, 2017, DRAFT Phase I/II Environmental Site Assessment, 945-1065 Carlsbad Village Drive, Carlsbad, California 92008, May." Notes Approximate Site Boundary 7-11