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CORRESPONDENCE - 75D
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CORRESPONDENCE - 75D
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6/6/2019 12:19:02 PM
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6/4/2019 2:59:49 PM
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City Clerk
Item #
75D
Date
6/4/2019
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The conduct of a Phase I ESA is a fundamental component of the due diligence process for projects <br />undergoing CEQA review. A Phase I ESA ensures that hazardous soil or groundwater conditions do not <br />exist that would pose a risk to construction workers or neighboring residents upon development. <br />Phase I ESAs are commonly included in CEQA documentation to identify hazardous waste issues that <br />may pose a risk to the public, workers, or the environment and which may require further investigation, <br />including environmental sampling and cleanup. Any conditions identified as hazardous in the Phase I <br />should be addressed through mitigation in a revised EIR Addendum. <br />Standards for performing a Phase I ESA have been established by the US EPA and the American Society <br />for Testing and Materials Standards (ASTM).' Phase I ESAs are conducted to identify conditions <br />indicative of releases of hazardous substances and include: <br />• a review of all known sites in the vicinity of the subject property that are on regulatory agency <br />databases undergoing assessment or cleanup activities; <br />• an inspection; <br />• interviews with people knowledgeable about the property; and <br />• recommendations for further actions to address potential hazards. <br />Phase I ESAs conclude with the identification of any "recognized environmental conditions' (RECs) and <br />recommendations to address such conditions. A REC is the presence or likely presence of any hazardous <br />substances or petroleum products on a property under conditions that indicate an existing release, a <br />past release, or a material threat of a release of any hazardous substances or petroleum products into <br />structures on the property or into the ground, groundwater, or surface water of the property. If RECs <br />are identified, then a Phase II ESA generally follows, which includes the collection of soil, soil vapor and <br />groundwater samples, as necessary, to identify the extent of contamination and the need for cleanup to <br />reduce exposure potential to the public. <br />Consistent with professional due diligence procedures, a Phase I ESA, completed by a licensed <br />environmental professional is necessary for inclusion in a revised Addendum to identify recognized <br />environmental conditions, if any, at the proposed Project site. A Phase II ESA should be conducted if the <br />Phase I indicates a recognized environmental condition. Any contamination that is identified above <br />regulatory screening levels, including California Office of Environmental Health Hazard Assessment's Soil <br />Screening Numbers', should be cleaned up in coordination with the California Department of Toxics <br />Substances Control(DTSC). <br />' http://www.astm.orx/Standards/E1527.htm <br />2 htto://oehha.ca.aov/risk/chhsltable.html <br />
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