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HomeMy WebLinkAboutCT 13-03; ROBERTSON RANCH-RANCHO COSTERA; RESPONSE TO DEH REVIEW AND 2ND ADDENDUM TO PROPERTY MITIGATION PLAN; 2013-10-31.1 w.a INC. - COUNTY OF SAN DIEGO DEPARTMENT OF ENVIRONMENTAL HEALTH SITE ASSESSMENT AND MITIGATION PROGRAM P.O. Box 129261 SAN DIEGO, CALIFORNIA 92112-9261 W.O. E6145.3-SC OCTOBER 31, 2013 VAPC# H39768-001 Li U I n Geotechnical' Geologic. Coastal • Environmental 5741 Palmer Way . Carlsbad, California 92010 • (760) 438-3155 • FAX (760) 931-0915 • www.geosoilsinc.com October 31, 2013 W.O. E6145.3-SC County of San Diego VAPC# H39768-001 Department of Environmental Health Land and Water Quality Division Site Assessment and Mitigation Program P.O. Box 129261 San Diego, California 92112-9261 Attention: Ms. Carol Fenner Subject: Response to DEH Review and 2 nd Addendum to "Property Mitigation Plan, Rancho Costera (Formerly Robertson Ranch West), Carlsbad, San Diego County, California 92010, Voluntary Assistance Case H39768-001," W.O. E6145.1-SC, dated October 24, 2011, by GeoSoils, Inc. Dear Ms. Fenner: On behalf of Shapell Homes, and in accordance with the County of San Diego Department of Environmental Health (DEH) Land and Water Quality Division, GeoSoils, Inc. (GSl) is providing this addendum letter of response to review comments by the DEH included in the letter dated April 26, 2012 (DEH, 2012). Unless specifically superceded herein, the conclusions and recommendations contained in GSl's reports and addendums (see Appendix A) remain pertinent and applicable, and should be appropriately implemented during planning, design, and construction. REVIEW RESPONSE For ease of review, the DEH (2012) review comments are repeated below in bold, followed by GSI's response. Review Comment 1: The discussion of contaminant characteristics (page 2) primarily describes the properties and potential health effects of toxaphene as a manufactured pesticide product. DEH acknowledges that little information is available on the characteristics of toxaphene when adhered to soil particles. The discussion should clearly make the distinction. Also, it should be stated that no air standards have been promulgated for toxaphene as a pesticide product or when it is present in dust. However, the California Human Health Screening Levels for soil do provide guidance as to the threshold concentrations to be considered when evaluating the potential effects of a contaminant from multiple exposure routes (i.e., dermal contact, inhalation, ingestion). GSI Response to Review Comment No. 1: Noted. The discussion herein (see the Updated Community Health and Safety Plan [Appendix B]), clearly makes the distinction, and also discusses the lack of information available on the characteristics of toxaphene when adhered to soil particles. GSI acknowledges the guidance in the California Human Health Screening Levels (CHHSLs) when evaluating the potential effects of a contaminant from multiple exposure routes (i.e., dermal contact, inhalation, ingestion), and has incorporated the intent of those guidelines into the proposed mitigation discussed herein. Review Comment No.2: The "Monitoring" discussion shall be updated to state that air particulate samples will be collected at the site perimeter and periodically tested for pesticides. [Please note that air particulate sampling alone will not satisfy requirements associated with County Air Pollution Control District (ACPD) Rule 55. Adequate watering of the site for dust suppression purposes, per the Community Health and Safety Plan, should address APCD requirements]. GSI Response to Review Comment No. 2: Acknowledged. The "Monitoring" discussion is updated herein (see the updated Community Health and Safety Plan [Appendix B]), including reference to County Air Pollution Control District (ACPD) Rule 55. Review Comment No. 3: The "Best Management Practices" discussion shall be accompanied by a site map that shows the types of BMPs that would be employed at specific locations in the event of a runoff-producing precipitation event during remedial excavation and grading operations. GSI Response to Review Comment No. 3: Acknowledged. The Site Map (Plate 1) shows the locations of the types of BMPs that would be employed at specific locations in the unlikely event of a runoff-producing precipitation event during remedial excavation of the impacted soil. A further discussion of BMP's is included in the updated Community Health and Safety Plan (Appendix B). County of San Diego W.O. E6145.3-SC Rancho Costera, Carlsbad October 31, 2013 File:e:\wpl2\e6100\e6145.3.rn21d GeoSoils, Inc. Page 2 SUMMARY OF PROPOSED MITIGATION As discussed with the DEH, owing to conflicts with the construction of the "land bridge" below the street, the proposed mitigation of the impacted soil is now proposed within other areas of the street right-of-ways. Maps and cross sections for the proposed burial of the impacted soil showing the revised locations and depths below finished surface are included herein as Plates 1 through 5. The top of the impacted soil will be covered by Mirafi 140 as a marker, and will be at least 2 feet below the deepest underground utility within the street right-of-way, and more than 7 feet deep. Thus, there will be a cover of clean soil or buffer ranging between about 7 and 24 feet above the impacted soil in the street right-of-way. The impacted soil will typically be placed at 50 feet or more above the regional water table, and in no case will it be less than 5 feet. Based on the approximate volume of 94,622 cubic yards of toxaphene impacted soil, GSI has planned on excavations ranging up to about 114,000 cubic yards for the placement of the impacted soil. Based on the available excavation, there is sufficient space in these areas to accomplish this and more, should additional impacted soil, although unlikely, be encountered during site grading. Other Street right-of-ways are proposed to be overexcavated (mined) if additional disposal is necessary (see Plate 1). LIMITATIONS Inasmuch as our study is based upon our review and engineering analyses and laboratory data, the conclusions and recommendations are professional opinions. These opinions have been derived in accordance with current standards of practice, and no warranty, either express or implied, is given. Standards of practice are subject to change with time. GSI assumes no responsibility or liability for work or testing performed by others, or their inaction; or work performed when GSI is not requested to be onsite, to evaluate if our recommendations have been properly implemented. Use of this report constitutes an agreement and consent by the user to all the limitations outlined above, notwithstanding any other agreements that may be in place. In addition, this report may be subject to review by the controlling authorities. Thus, this report brings to completion our scope of services for this portion of the project. County of San Diego W.O. E6145.3-SC Rancho Costera, Carlsbad October 31, 2013 File: e:\wp12\e61O0e6145.3.rn2td GeoSoils, Inc. Page 3 This opportunity to be of service is sincerely appreciated. Should you have any questions, please do not hesitate to contact the undersigned. Respectfully submitted, GeoSolls, Inc. /'ko VA L iiiiIj"\ : 0 : \ e Certified ) I Enginerfnp nkhn PeokVist / eering Geologistj 1340, CHG 532 JPF/jh Attachments: Appendix A - References Appendix B - Community Health and Safety Plan Plate 1 - Site Map Plates 2 through 5- Generalized Cross Sections Distribution: (1) Addressee (1) Shapell Homes., Attention: Mr. Darius Fatakia (1) O'Day Consultants, Attention: Mr. George O'Day. County of San Diego W.O. E6145.3-SC Rancho Costera, Carlsbad October 31, 2013 Fiie:e:\wpl2\e6100\e6145.3.rn2td GOdS Inc. Page 4 APPENDIX A REFERENCES GeoSoils, Inc. APPENDIX A REFERENCES County of San Diego, Department of Environmental Health, 2011, Comments on Voluntary Assistance Case H39768-001, dated April 22. 2007, Conditional concurrence with revised workplan, Robertson-Ranch - Planning Areas 12 and 13, 5056 El Camino Real, Carlsbad, CA 92010, Voluntary Assistance Case H39700-001, dated January 25. 2006, Comments on proposed investigation of agricultural chemical residue, Robertson Ranch - Planning Areas 12 and 13, 5056 El Camino Real, Carlsbad, CA 9210, Voluntary Assistance Case H39700-001, dated December 20. GeoSoils, Inc., 2012, Response to DEH Review and Addendum to "Property Mitigation Plan, Rancho Costera (Formerly Robertson Ranch West), Carlsbad, San Diego County, California 92010, Voluntary Assistance Case H39768-001," (WO. E6145.1-SC, dated October, 2011), W.O. E6145.2-SC, dated February 24 2011 a, Property mitigation plan, Rancho Costera (formerly Robertson Ranch West), Carlsbad, San Diego County, California 92010, Voluntary Assistance Case H39768-001, dated October 10. 2011 b, Supplement to the updated geotechnical investigation for Rancho Costera (Formerly Robertson Ranch West Village), Carlsbad, San Diego County, California, W.O. 6145-Al-SC, dated June 6. 2011 c, Work plan for property mitigation plan, Rancho Costera (formerly Robertson Ranch West), Carlsbad, San Diego County, California 92010, Voluntary Assistance Case H39768-001 W.O.E6145.1-SC, dated May 4. 2010a, Addendum No. 2, update phase I environmental site assessment and supplemental agricultural residue survey, Robertson Ranch West, Carlsbad, San Diego County, California 92010, W.O. E6145-SC, dated December 9. 2010b, Addendum to update phase I environmental site assessment and supplemental agricultural residue survey, Robertson Ranch West, Carlsbad, San Diego County, California 92010, W.O. E6145-SC, dated November 1. 2010c, Update phase I environmental site assessment and supplemental agricultural residue survey, Robertson Ranch West, Carlsbad, San Diego County, California 92010, W.O. E5491.2-SC, dated October 25. GeoSoils, Inc. 2007a, Detailed agricultural residue survey, Robertson Ranch West, Carlsbad, San Diego County, California 92010, W.O. E5491.2-SC, dated October 17. 2007b, Updated phase I environmental site assessment and limited agricultural residue survey, Robertson Ranch West, Carlsbad, San Diego County, California 92010, W.O. E5491-SC, dated July 27. 2007c, Revised detailed agricultural chemical residue survey, APN 208-010-26, Planning Area 12 - 13.44 acres, and Planning Area 13 - 6.92 acres, Robertson Ranch West, Carlsbad, San Diego County, California 92010, Voluntary Assistance Case H39700-001, W.O. E5247.1-SC, revised date June 7. 2006a, Revised work plan for detailed agricultural chemical residues in soil, APN 208-010-36, Planning Area 12- 13.44 acres, and Planning Area 13- 6.92 acres, Robertson Ranch West, Carlsbad, San Diego County, California 92010, Voluntary Assistance Case H39700-001 , W.O. E5247.1-SC, dated December 27. 2006b, Work plan for detailed agricultural chemical residues in soil, APN 208-010-36, Planning Area 12-13.44 acres, and Planning Area 13-6.92 acres, Robertson Ranch West, Carlsbad, San Diego County, California 92010, W.O. E5247.1-SC, dated December 4. 2006c, Update phase I environmental site assessment and limited agricultural residue survey, Planning Area 12- 13.44 acres, and Planning Area 13- 6.92 acres, Robertson Ranch West, Carlsbad, San Diego County, California 92010, W.O. E5247-SC, dated August 5. Shapell Homes Appendix A Fi1e:e:\wp12\e6100\6145.3.rn2td GeoSoils, Inc. Page 2 APPENDIX B COMMUNITY HEALTH AND SAFETY PLAN LI I I GeoSoils, Inc. COMMUNITY HEALTH AND SAFETY PLAN Site Identification The subject site ("the site") is approximately 201 acres, located within the City of Carlsbad, California. The overall project, Rancho Costera, is bounded by El Camino Real on the West, Tamarack Avenue on the North, existing residential development to the east, and open space to the south. Topographically, the site consists predominantly of several, broad, north to south trending, low ridge lines separated by intervening south flowing drainage. These ridges all appear to terminate up-gradient, along an east west trending ridge, atop a large north facing, natural slope that descends to the south side of Tamarack Road. Overall relief throughout the site varies from an approximate elevation of 220 feet above Mean Sea Level (MSL) within the northern portion of the property, down to an elevation of approximately 45 to 50 feet MSL within the southern, and western portions of the property. Natural slopes vary from on the order of 30 to 120 feet in height, with the largest slopes located along the northern site boundary, occurring at gradients on the order of 3:1 to 2:1 (horizontal to vertical [h:v]), and on the slopes flanking broad north-south ridgelines, ranging on the order of 4:1 to 6:1 (h:v). The majority of the site is used for agricultural purposes, primarily within gently sloping areas. Steeper slopes are relatively undeveloped and support native vegetation. PA's 11, 12 and 13 have been previously graded into super pads. Assessor parcel number associated with the site is 208-010-40. The site is listed as an open case with the San Diego County Department of Environmental Health (Case #H39768-001). The site has been proposed to be redeveloped with a residential subdivision along with parks and a commercial center. Evaluation of Potential Public Exposure to Hazards The site consists of approximately 201 acres of land which has been predominantly used for agricultural purposes since prior to 1930. Since 2006, numerous subsurface pesticide investigations have been conducted on the site resulting in the collection of a total of 104 soil samples for the analysis of residual pesticides. Pesticide analysis identified localities where the presence of toxaphene, at concentrations that exceed the California Human Health Screening Levels (CHHSLs) for residential soils. Other pesticide constituents, including 4,4-DDD, 4,4-DDE, 4,4-DDT, and Heptachlor were identified at concentrations below action levels indicated by the CHHSLs. Based on the results of the investigations, soil impacted with toxaphene at concentrations above the CHHSLs existed from the surface to a maximum depth of ±3.0 feet below ground surface. However, the vast majority of the toxaphene impacted soil exists from the surface to a maximum depth of 1 to 2 feet below the ground surface. The depth of migration of the pesticides appeared to be primarily due to site grading during agricultural activities. Soil encountered during the investigations generally consisted of brown to olive gray sandy clay to clayey silty sand, and was generally moist to wet. GeoSoils, Inc. The proposed property developer (Shapell Homes) plans to excavate and stockpile onsite soil with toxaphene concentrations above the site cleanup levels indicated above (CHHSLs). All soils with toxaphene concentrations above the residential CHHSLs (460 pg/kg), will be placed in excavations created onsite within the street right-of-way, and have a minimum cover of 7 to 24 feet, as determined by the deepest utilities and/or storm drain, provided by the site civil engineer. This soil will be placed within street right-of-ways, beneath proposed streets, and at least 5 feet above the highest anticipated groundwater level. Grading of the site will involve heavy earth-moving equipment to excavate the impacted soil and deposit these soils within specifically placed excavations. Clean imported fill material will cover the impacted soil and compacted, upon which improvements can be safely placed. The excavation and movement of toxaphene impacted soil will pose an exposure concern. Specifically, the exposure of toxaphene through inhalation, dermal contact, and ingestion or airborne dust particles would pose the greatest public health concern. Additionally, noise and hazards associated with large moving equipment will also presented by earth grading operations. Based on the site's location within a predominantly residential area, proper protocols will need to be in place during the remedial activities to reduce exposure to potential health hazards. Contaminant Characteristics Toxaphene was the only pesticide found at the site at concentrations that exceeded State and Federal screening levels. All other pesticides were found to be significantly below levels which pose as a human exposure concern (CHHSLs). Therefore, this narrative will focus on the characteristics and occurrence of toxaphene contaminated soil. Toxaphene is non-combustible, highly toxic when ingested in sufficient concentrations, and has a strong bond to soil grains. Based on onsite analytical testing, toxaphene is not water soluble and, therefore, does not migrate or represent a concern for groundwater contamination. Toxaphene does not diffuse in air; therefore, if buried, contaminant vapor migration is not a concern. The Occupational Safety & Health Administration (OSHA) recommended a maximum average amount of air exposure of toxaphene to workers to not exceed 0.5 micrograms per cubic meter of air (mg/m3) per 8-hour workday over a 40-hour work week. The National Institute of Occupational Safety & Health (NIOSH) currently does not have a recommended limit for up to a 10-hour workday over a 40-hour workweek. According to the International Agency for Research on Cancer (IARC), toxaphene is classified as Group 2B carcinogen (possibly carcinogenic to humans [PARC, 2009]). The National Toxicology Program (NTP) has determined that toxaphene is reasonably anticipated to be a human carcinogen (NTP, 2005), and the United States Environmental Protection Agency (US EPA) has classified toxaphene as a B2 carcinogen (probable human carcinogenic [IRIS, 2010]). The American Conference of Governmental Industrial Hygienists (ACGIH) has classified toxaphene as an A3 carcinogen (confirmed animal carcinogen with unknown relevance to humans [ACGIH, 20091). Community Health and Safety Plan W.O. E6145.3-SC File:e:\wpl2\env\e6100\e6145.3.uctiasp GeoSoils, Inc. Page 2 The U.S. Department of Agriculture (USDA) prohibited all uses of toxaphene in 1990. In 1982, however, the US EPA cancelled the registration of toxaphene for use as a pesticide, except for use on livestock, in emergency situations. According to Agency for Toxic Substance and Disease Registry (ATSDR), no studies are available on the effects of acute inhalation exposure to toxaphene in humans or animals (ATSDR, 1996). Acute oral exposure to toxaphene in humans results in Central Nervous System (CNS) stimulation, with the major effect begin convulsive seizures. The dose necessary to induce nonfatal convolutions in humans is approximately 10 milligrams per kilogram body weight per day (mg/kg/day [ATSDR, 1996]). Animal studies have reported effects on the liver, kidney, and CNS from acute oral exposure to toxaphene. Additionally, animal studies have reported development effects, including behavior effects and immunosuppression, in offsprings of rats exposed orally to toxaphene. Several studies have reported no reproductive effects from oral exposure to toxaphene in rats (ASTDR, 1996). Please note, however, that there is little information available on the characteristics of toxaphene when adhered to soil particles. Methods of Exposure The primary onsite source of contamination was the legal application of agricultural pesticides. The secondary source of contamination is the soil grains that the pesticides have bound to. The primary mode of transportation is wind and earth-moving operations during proposed grading. Additionally, a less likely mode of transportation is bioaccumulation of pesticides in plant material such as edible fruit and vegetables. The direct exposure to toxaphene impacted soil through ingestion, inhalation, and dermal contact is the main human health concern. Activities that involve the handling of impacted soil, such as gardening and home improvements that involve excavation work, may result in exposure. Bioaccumulation results in the uptake of chemical pesticides into edible fruits and vegetables, and is not known to occur onsite. The burial of the impacted soil to the depths proposed below the ground surface, and as determined by the deepest utilities and/or storm drain, provided by the site civil engineer. This would eliminate the risk of plant uptake and human contact of toxaphene at concentrations above the CHHSLS. Inhalation of airborne dust is another route for exposure to toxaphene. The US EPA Integrated Risk Information System has not published a reference concentration for toxaphene for chronic inhalation exposure. Also, no air standards have been promulgated for toxaphene as a pesticide product or when present in dust adhered to soil particles. Due to the chemical characteristics of toxaphene vapor intrusion, leaching, and groundwater impacts are not applicable concerns onsite. Monitoring To date, GSI is unaware of any monitoring devices that detect concentrations of toxaphene adhered to soil particles, in real time. Nonetheless, air particulate samples will be collected Community Health and Safety Plan W.O. E6145.3-SC File:e:\wpl2\env\e6100\86145.3.uchasp GeoSoils, Inc. Page 3 at the site perimeter. Temporary weather stations will be placed at three locations near the property perimeter during remedial grading operations for impacted soil. One of the stations will be equipped with the equipment necessary to monitor and record temperature, wind speed and direction, and precipitation volumes seven days a week. The two remaining stations will be equipped to monitor wind speed and direction. The aerosol monitors will be properly calibrated and in good working order. The recorded data will be provided to DEH for review when requested, and will be appended to the final remediation summary report. A high-volume air sampler will be installed at each of the weather stations and operated during the daytime seven days a week. The particulate filters for the samplers will be periodically tested for organochlorine pesticides. Adequate watering of the site for dust suppression purposes should also address County Air Pollution Control District (ACPD) Rule 55. Confirmation Sampling In areas of concern, once excavated to the planned dimensions, confirmation soil samples will be collected from the base of the excavations at an approximate frequency of one for every 50- by 50- foot area. Confirmation soil samples will also be collected from the sidewalls of the excavations at an approximate frequency of every 50 linear feet. Mass I grading will not continue until test results indicate that the constituents of concern are below residential CHSSLs (the cleanup goal). The confirmation samples will be collected directly into laboratory-provided sampling jars, properly labeled, and placed in a chilled cooler for transport to the laboratory under chain-of-custody protocol. The samples will be analyzed for organochiorine pesticides (USEPA Test Method 8081A, using a 24-hr rush turnaround. I Engineering Controls The following engineering controls will be utilized in order to reduce the risk of human I exposure to toxaphene contaminated soil during remedial activities: Dust During excavation and stockpiling activities, copious amounts of water must be applied to the soil in order to suppress dust particles from becoming air-borne. Additionally, toxaphene impacted soil must not be disturbed if winds exceed 13 miles per hour (mph). All stockpiled soils must be covered with heavy grade plastic sheets while water suppression is not employed, particularly during non-working hours. Adequate watering of the site for dust suppression purposes should address County Air Pollution Control District (ACPD) Rule 55, as indicated above. Water should minimally be sprayed prior to daily work activities, and during excavation/loading and placement activities. Watering equipment will be continuously available to provide proper dust control. Community Health and Safety Plan W.O. E6145.3-SC File:e:\wpl2\env\e6100\e6145.3.uchasp GeoSoils, Inc. Page 4 Site Security The site will be fenced and gated, limiting access to only those authorized to be onsite. Noise Equipment operation times will'be dictated by the City of Carlsbad, Zoning Ordinances. The site is surrounding by residential neighborhoods. It is anticipated that noise may be an issue which will require some level of cooperation between the developer and the surrounding neighborhoods, as on any construction project. Open Excavations Given the size of the potential excavations, it will be required to have them remain open overnight. As a result, safety for entering an exaction due to illegal entry is a concern after hours. Every effort will be made to backfill excavations at the end of each workday, but for those that remain open, proper fencing and flagging of the excavation will occur after operating hours. In addition, proper slopes will be maintained as well as one open end for ease of entry and exit from the excavations. Soil Management To ensure that impacted soil is not carried offsite, all vehicles and equipment should be inspected prior to exiting the site. If significant amounts of soil are trapped within the tires or under-carriage of vehicles, the soil should be removed prior to the vehicle exiting the site. Track-out gates or gravel beds should be employed at each egress point. During and at the end of each day, any soil deposited on El Camino Real outside the exit of the site should be swept up and returned to the site for proper management. Best Management Practices If site development is required during rainy periods, care should be taken to minimize the negative effects. Typically, the City has recommended that no work be conducted when the potential for rain is above 40 percent. Reasonable judgment should be used to determine the significance of the potential rainfall event and how it might affect the remedial grading activities. If a significant rainfall event is anticipated or occurs during construction operations, necessary measures must be taken to minimize erosion of stockpiles and limit soil erosion from offsite migration. As is the standard during construction, the developer will retain a consultant to produce a Storm Water Pollution Prevention Plan (SWPPP), which will include the overall project. In the event of a runoff- producing precipitation event, the Best Management Practices (BMPs) that would be employed at specific locations during remedial excavation and grading operations are shown on the Site Map, Plate 1. Since combinations of BMPs would already be in place for the overall project (i.e., diversion ditches, fiber rolls, etc.), and considering that during proposed mitigation, the excavations would be below grade, the BMPs would consist of silt fences and/or filter roll barriers used in conjunction with the site SWPPP, which would Community Health and Safety Plan W.O. E6145.3-SC File: e:\wpl2\env\e6100\e6145.3.uchasp GeoSoils, Inc. Page 5 also include routine protection of storm drain inlets with filter fabric and sand/gravel bag barriers. Site Safety Ofticer The designated project superintendent chosen by Shapell Homes will serve as the Site Safety Officer. GSI will assist the Site Safety Officer in areas where they are unfamiliar with site safety. The job of the Site Safety Officer will be to monitor dust control and ensure that the site is only accessed by authorized personnel. In the event of an emergency, the Site Safety Officer will have the authority to shut down site activities and the knowledge to notify the appropriate emergency responders. Emergency Planning Toxaphene is non-flammable and does not represent a fire or explosion concern. In the event of an emergency where site activities are halted, necessary measures must be taken to ensure that contaminated soil does not leave the site. All stockpiles must be covered and trenches must be fenced. If in the event of an emergency, the Site Safety Officer must notify the following agencies or individuals: City of Carlsbad Engineering Inspector: (760) 438-4178 City of Carlsbad Fire Department: 911 or (760) 931-2141 San Diego Department of Environmental Health: Carol Fenner - (858) 505-6896 Public Notification Prior to the implementation of the proposed work, public notices will be mailed or hand-delivered to neighboring residences contiguous to the subject property. The notices will identify the proposed work, days and hours of operation, and an estimated schedule of the project. Details will include: Site Safety Officer's and GSI's contact information, identification of potential concerns including dust and noise; a brief description of planned activities, and the Proposition 65 Warning of the potential exposure to chemicals known or suspected by the State of California to cause cancer. Notices will also be placed on the fence surrounding the site's perimeter immediately prior to start of construction activities. GSI will prepare a Public notification Letter for distribution to the neighbors using the example provided in the most recent San Diego County Department of Environmental Health Site Assessment and Mitigation Manual. Traffic Control Plan The site is located within a residential area of Carlsbad. The main roadway to access the site (El Camino Real) consist of a divided four-lane paved road with no parking allowed on the shoulder. Additionally, there are no sidewalks along the north/east side El Camino Real. Trucks and all other vehicles should be aware of the following precautions: Community Health and Safety Plan W.O. E6145.3-SC File:e:\wpl2\env\e6100\e6145.3.uchasp GeoSoils, Inc. Page 6 I The maximum speed limit on 4-lane major roads is 55 miles per hour (mph). Large trucks should limit their speed to 45 mph to account for their longer stopping distance; Due to the lack of sidewalks, residents may be walking in the street. Drivers of trucks and other vehicles must be alert at all times. Community Health and Safety Plan W.O. E6145.3-SC FiIe:e:\wpl2\env\e6100\e6145.3.uchasp GeoSoils, Inc. Page 7 SPECIFIC SITE HEALTH AND SAFETY PLAN FOR PROPOSED GRADING, RANCHO COSTERA PLANNING AREA PA-3 THROUGH PLANNING AREA PA-1 1 CARLSBAD, SAN DIEGO COUNTY, CALIFORNIA 92010 EMERGENCY NOTIFICATION REFERENCE Emergency Response - Fire/Police/Ambulance ...........................911 Hospital - Tr-City Medical Center .............................(760) 724-8411 Address: 4002 Vista Way, Oceanside, California Directions: Take El Camino Real north. Proceed to Vista Way (under the Highway 78 overpass). Proceed east on West Vista Way then to the entrance of Tr-City Medical Center, on the north side of West Vista Way and Highway 78. I Location of the hospital site in the Thomas Guide for San Diego County is page 1107, coordinates Bi. Poison Control Center .......................................(619) 543-6000 1-800-876-4766 County of San Diego Department of Health Services Department of Environmental Health Land and Water Quality Division .........................................(858) 505-6700 Client Mr. Darius Fatakia ......................................(714) 912-5415 (818) 324-6204 Operations Consultant Mr. John Franklin, GeoSoils, Inc ........................... .(760) 438-3155 I (760) 250-5835 Standard Procedure for Reporting Emergencies I Provide the following information when calling for assistance in an emergency situation: Name, phone number, and location of person making call Number of persons exposed or injured Nature of emergency Actions already taken Remain on the phone unless instructed otherwise. GeoSoils, Inc. I INTRODUCTION This Community Health and Safety Plan (CHSP) has been developed specifically for the assessment activities including the excavation of elevated levels of pesticide in soil, to be performed on Planning Area 2 through Planning Area 10, in Carlsbad, San Diego County, California. It addresses potential public health concerns and provides guidelines to reduce the potential for exposures and/or injuries to the surrounding public from the activities to be performed at the subject site. This H&S Plan is designed to be specific with regard to the proposed onsite activities and the potential for encounters with hazardous materials and hazardous situations. However, due to potential variations of anticipated conditions at the site, it should be noted that unforeseen situations could arise during the performance of the environmental services that would necessitate a deviation from this CHSP. Thus, provisions will be made to allow modifications to the CHSP when appropriate. SITE LOCATION It is our understanding that the subject property is comprised of approximately 201 acres, located in the northeasterly part of the Carlsbad, San Diego County, California. Overall, the agricultural area is located west of College Boulevard and north of El Camino Real and east of Tamarack Avenue (see Figure 1). POTENTIAL ENVIRONMENTAL EFFECTS Potential chemical, physical, and operational hazards identified by GSI and described in this document are not anticipated to cause any unsafe or unhealthy environmental effects. Should conditions be encountered that require protective measures other than those outlined for this project, onsite activities will be suspended or modified until the appropriate control methods can be implemented. LIMITED PUBLIC NOTIFICATION The limited public notification program will consist of informing affected entities, as identified by representatives of the consultant and the client, of the dates and nature of the proposed activities. Specific Site Health and Safety Plan W.O. E6145.3-SC FiIe:e:\wp9\env\e6100\e6145.3.ssh GeoSoils, Inc. Page 2 I -"SI TE •. '' ,, A, 7-3 I J) &i: j5J • 1 . wUll : 2055 3000 46 Base Map: TOPO!0 ©2003 National Geographic, U.S.G.S San Luis Rey Quadrangle, California -- San Diego Co., 7.5 Minute. dated 1997, current 1999. SI TE lq IN QA X. ng -' -I •e N I I 4 , .3i , / - '- . - ----.- - Base Map: The Thomas Guide. San Diego Co., Street Guide and Directory, 2005 Edition, by Thomas Bros. Maps, pages 1106 and 1107. ReproiAced wiTh permission aranlod 51 Thomas Bros Maps This map is copyrighted by Thomas Bros Maps It is unlawful TO copy or reproduce all or ary part thereof whethm for personal use cy resale. without permission. All nghfs resenvea GeoSoils, The. w.o. E6145-SC A SITE LrAOTION MAP I N Figure 1 OVERVIEW OF POTENTIAL HAZARDS Toxaphene is the contaminant of concern at the site. Potential chemical, physical, and operational hazards identified by the consultant and described in this document are not anticipated to cause any unsafe or unhealthy environmental effects to the public. The public will be excluded from the area of the soil removal activities. Symptoms of overexposure to soil affected by toxaphene usually occur after a lengthy exposure. The concentrations required to produce the symptoms of an overexposure generally depend upon the type of exposure (ingestion, inhalation, or skin contact), the duration of each exposure and/or number of exposures, and the concentration. Routes of Exposure Inhalation, ingestion, skin absorption, and skin and/or eye contact. Symptoms Symptoms of overexposure may include but are not limited to eye, nose and respiratory system irritation, giddiness, headache, nausea, staggered gait (walking style), fatigue, anorexia (loss of appetite), lassitude (weakness, exhaustion), dermatitis (inflammation of the skin), bone marrow depression (blood cell production depression), and abdominal pain. Hazard Control There will be no eating, drinking, or smoking during remedial grading of the contaminated soils. During grading operations, personal protection (i.e., clothing) is not required, unless contaminated soils are being handled by individuals. Based upon previous laboratory test results and the chemical nature of subject agricultural residues, contamination onsite appears to be non-volatile; nonetheless, air monitoring is proposed. Other hazards/annoyances that could develop during the field operations include noise created by the operation of heavy equipment, such as a scraper, dozer, backhoe, or track hoe, and the chance of fire or explosion. The potential for the presence of explosive vapors or a fire from these soil excavation activities is considered minimal. Fire protection shall be provided by at least a 20-pound ABC-type portable fire extinguisher readily available to trained personnel onsite, and located within 10 feet of spark-producing operations. Personnel shall also be familiar with the procedures for summoning emergency assistance from the fire department. Smoking, open flames, or other ignition sources will not be permitted within 25 feet of the work area. Noise hazards are often created around large equipment (e.g., scrapers, dozers, backhoes and drill rigs) that generate excessive noise. The effects of noise can include: personnel being startled, annoyed, or distracted; physical damage to the ear, pain, and temporary Specific Site Health and Safety Plan W.O. E6145.3-SC File:e:\wp9\env\e6100\e6145.3.ssh GeoSoils, Inc. Page 4 or permanent hearing loss; communication interference that may cause increased potential hazards due to the inability to warn of danger and proper safety precautions to be taken. Despite the identification of these potential hazards, it is not anticipated that noise levels will exceed existing safety standards. The operational safety hazards that could exist on the site including being hit by equipment, falling objects, falling in holes or ditches, and slippery surfaces. Heavy power equipment shall be operated by experienced and certified (where applicable) operators and shall be locéted and operated in a safe manner. When heavy equipment is moved on or off the site, a spotter shall assist the driver in watching for and locating above ground obstacles, pedestrian traffic, vehicular traffic, and other hazards. SITE OPERATING PROCEDURES Procedures for the conduct of site visitors during the performance of the soil removal/remedial excavation and associated activities at Rancho Costera have been established to reduce the possibility of injury resulting from exposures to the hazards of concern. These procedures require the cooperation of all onsite personnel and visitors during the project and will be strictly enforced by the Site Manager/Safety Officer. No one shall be allowed to enter the site without the required authorization from either Mr. Darius Fatakia, Project Manager, or the consultant (GSI). Onsite personnel and visitors will also be required to check in with the Site Manager/Safety Officer when entering the site and check out when leaving the site. EMERGENCY RESPONSE/PLANNING Prior to beginning field activities, the Project Manager and the Site Manager/Safety Officer shall plan emergency procedures. Initial planning includes establishing an alarm system (e.g., horn) and the best means for evacuation from work areas in the event of a catastrophic event (e.g., explosion, fire, etc.). Onsite personnel shall also be informed of the location of the telephones and other communication devices located onsite. Specific Site Health and Safety Plan W.O. E6145.3-SC File: e:\wp9\env\e6100\e6145.3.ssh GeoSoils, Inc. Page 5 I / I : \ LNJ ( 4V \/.45"y •i' /1 / N \ 1 ed under the observation testing of CS! Immo im (circled where buried T / / /xvs / JTJJ \ ,) deposits (circled where buried) V V J X ation (circled where buried,) •V' Motion ' • JV V V V____ ii j4 / J V4 V J V ' ' ., V V / VV VVV .V/ 1/ I, :'eak Volcanics t0nd Cretaceous gronl6cs (circled where burled) Ile "Jot J~ V,8c I 881 f I87 58 r 1' : :; uncertain) / TS PA-23B Tsa 77 Tsa /1 : /rail' of removal fee) •''' .# /1 :- \ // // 7sa in of aeolooic cros.5 section Qa in of 187 air monitoring station of proposed placement of impacted soil with estimated disposol quanqv a for the placement of impacted soil with estimated disposal quantity ,/ 'V yds 3 'V / n of silt fence and/or filter roll barrier for removal of impacted soil - ' ', - I /" < < td / "N / I1 /18\ct - E its 1,97 n of silt fence and/or filter roll barrier for the placement of impacted soils //' - 77 ZA now ±3,4695 yds 3 w of previous placement of impacted soil (Cs!, 2008) - / •'—' / * / ñ '7 \ 74ir " * Tsa / 66 ioo / -_ o - - - -2070 17,3 / / Y PA mw5 / ±26450 yds i sa 17 S d / 17 Tsa A Tr C7 x 40 yds 151 Qa!' AWN OOSCLM isa PAmffo Tsa ARM Q t % s a T x X47Z OBSCUM Pbs sa PA =8 PA / T Wal sa Qal' 1322 1 5 I Qal 0 x "Ars"L x Qt bd PA4 X Mir NOT A PART x 421 isa FFF sa Q t 40 Qa x At, X), XA x xj" AW x Ak AW 51M LAC x 70 guy A PA LM MILL LZJ V0 PA2 1 L 4J r / 'V - - - -- - V - /42 NO V I 14 Qt GV sa XIM x 407 105 1 PA 13 Q Oat % S for G discussion of grading this GV ATC PA 11 n1.*_f7.,zA rofm- in r.-ql .19nnqh) Ar For a discussion of qroding in this 4KV N~ V7 I aid / / -- / — - ----- ±5,4312yds3 ' G' - I - -- I area, please refer to 65/ '2008a / $ Qt rs X 47S XMI WH q~ J" 7, OW NJ 12 j 4W Xsw" Non AUX_ groding in this S1 (2008b x Z:17 AN 71 424 aS - " S t $74 , cv 42$ — _____ _________ -5- —I- 5-.. 5 / a : —ts x 4" - - . - — -- ----ç-- .--.----- . ......— *1 .,.: - - - - ...." - / • - - - - ' I A c . '. / I "j' a ' ' . , , \. " - Qt ,/' - w - cv 676 - -- Bum • — S Qt i C / /1 • '">" .• - -. jWJr NMI Ir 1WH - -.:kl,,. .. Z_*_,_-_ ,. / /- - - • I I 421 Qa - - NOT A PART NOT A PAR AC -JAW x 040 400 471 497 4524k - - £1 ?06 - - • . - V 7% • CS.' • .zxs b . "*, . .C4F sss • - ' l4 422 4LI AC SW $77 11.1 .$ S .115 515 j .CSO ' _- -.000 420 0000 000 491 x • as 40 c0 a - as • 1Sf 0 __5_ ••Sf I ' ' "* Q t $57 455 - -- 5- - - a - - - • 5 -5- -- S - - 5- - -5--- . •.CSI *318 ( ( )..S5 • ' 4 ,6 , /xs . - ,#a1 q X11 - - - - 6Sf 3d V •__/' - 'S54•4 Oal " ,/, - " efi ALL LOCATIONS AREAPPROXIMATE - 55_ •-.' , 5/Vf FH - -S - - "$52 \•' '1 .',, ' This document or Ole is not apart of the Construction - •.o •s N Documents and should not be relied upon as being an - accurate depiction of design. REVISED: 5/04/2012 I C--i1 U \r1A1z \r,* -z c-i' GRAPHIC SCALE 100 0 50 100 200 1"= 100' Xrefs: I OO7AMAP I OO7WSTR; 1007atp01