HomeMy WebLinkAboutEPA Close Out LetterFrom:KPiguee@tustinca.org
To:Robert.Howard@lw.com; dkendig@woodruff.law
Cc:NBernard@tustinca.org
Subject:FW: EHU Calls and Close Out
Date:Tuesday, July 29, 2025 11:51:15 AM
FYI
From: Ota, Christopher A CIV USN NAVFAC SW SAN CA (USA) <christopher.a.ota.civ@us.navy.mil>
Sent: Tuesday, July 29, 2025 11:19 AM
To: Micucci, Michelle@DTSC <Michelle.Micucci@dtsc.ca.gov>; Christie Bautista
(Christie.Bautista1@dtsc.ca.gov) <Christie.Bautista1@dtsc.ca.gov>; Darwin Cheng
(DCheng@ochca.com) <DCheng@ochca.com>; ChinsioKwong, Regina
<RChinsioKwong@ochca.com>; Jason Low <JLow@aqmd.gov>; Piguee, Kenneth
<KPiguee@tustinca.org>; ppakbin@aqmd.gov
Cc: Colin M. Cummings (Colin.Cummings@iem.com) <Colin.Cummings@iem.com>; Chammas, Guy A
CIV USN NAVFAC SW SAN CA (USA) <guy.a.chammas.civ@us.navy.mil>; Perry, Charles L CIV USN
(USA) <charles.l.perry6.civ@us.navy.mil>; Anderson, Scott D CIV USN (USA)
<scott.d.anderson11.civ@us.navy.mil>; Ben Castellana (castellana.ben@epa.gov)
<castellana.ben@epa.gov>; Harry L . Allen (Allen.HarryL@epa.gov) <Allen.HarryL@epa.gov>;
Mananian, Eileen (Eileen.Mananian@dtsc.ca.gov) <Eileen.Mananian@dtsc.ca.gov>; Dreyer, Marie G
CIV USN BRAC PMO SAN CA (USA) <marie.g.dreyer2.civ@us.navy.mil>
Subject: FW: EHU Calls and Close Out
EHU Members,
My apologies for not forwarding this sooner. Below is an email from EPA stating that the Navy
and it’s contractors (i.e. City of Tustin) have met the requirements of the Notice of Federal
Response Action letter dated November 28, 2023 and that the EPA has “no further concerns,
provided that the state and local agencies have no additional issues regarding the time-critical
removal at the site.”
The response action reports currently being prepared by the City of Tustin (for off-site) and
Navy (for onsite) will summarize activities to date and aim to provide the local agencies (i.e.
DTSC, SCAQMD, and OCHCA) with the information needed to close out the response action.
We will continue to keep you informed on the progress of the reports, so your agencies can
plan to conduct their reviews.
Please let me know if you have any questions.
Respectfully,
Christopher A. Ota
Remedial Project Manager
Former MCAS El Toro and Tustin
Navy BRAC PMO West
619.524.4474
From: Castellana, Ben <castellana.ben@epa.gov>
Sent: Tuesday, May 20, 2025 4:01 PM
To: Ota, Christopher A CIV USN NAVFAC SW SAN CA (USA) <christopher.a.ota.civ@us.navy.mil>;
Allen, HarryL <Allen.HarryL@epa.gov>
Cc: Colin M. Cummings (Colin.Cummings@iem.com) <Colin.Cummings@iem.com>; McCoy, Celeste
<McCoy.Celeste@epa.gov>
Subject: [Non-DoD Source] RE: EHU Calls and Close Out
Hi Chris,
Our concerns about the Tustin Hangar Fire incident are outlined in the 11/28/2023 Notice of Federal
Response Action. The salient items at the time were:
Provide a Work Plan that describes strategy for the removal and the disposal facilities to be
used.
Provide a Health and Safety Plan (HASP) that meets the requirements pursuant 29 CFR
1910.120(b)(4).
Provide a Sampling and Analytical Plan (SAP) for all sampling activities including hazardous
waste characterization, structural contamination assessment, soils assessment (surface and
subsurface).
Provide proof of compliance with 29 CFR 1910.120: Hazardous Waste Operations and
Emergency Response (HAZWOPER) for all contractors. Proof of compliance must include: the
written safety and health program plan and all ancillary plans required pursuant to 29 CFR
1910.120(b)(1); proof of a medical surveillance program (29 CFR 1910.120(f)); and proof of
training (29 CFR 1910.120(e)).
Maintain Site security and restrict Site access.
Prevent all discharges of hazardous substances from Site.
Characterize, collect, and remove all CERCLA hazardous substances at the Site, as defined in
paragraph 1 in the preamble above. The predominant pollutant/contaminant of concern is
debris from the burning hangar that has left the footprint of the hangar, but may also include,
and is not limited to, building debris, facility equipment, product inventory, chemical
feedstocks, hazardous wastes, free liquids, water collection and treatment system,
contaminated waters and surface/subsurface soils.
All hazardous wastes removed during the emergency phase must be properly manifested to
an appropriate disposal facility. Provide Transportation Plan and advance notification to OSC
(approx. 48 hours) of any shipments of hazardous substances or hazardous wastes off-site.
Provide copies of all waste manifests, bills of lading and all other shipping papers associated
with the transportation of materials from the emergency response, off Site to OSC.
Maintain an IMT structure through the removal of debris from the areas outside the hangar
footprint, and stabilization of the remaining debris at the hangar. Monitor the hangar site in
accordance with the Incident Air Monitoring Plan produced through the IMT. Plan for removal
of debris with appropriate state and local regulatory agencies/stakeholders, including air
monitoring requirements laid out in the Incident Air Monitoring Plan.
It is my opinion as the EPA OSC that the Navy and its contractors have met these requirements
through the many planning documents, deliverables, and response effort at the site. The EPA
Superfund Emergency Response Planning and Preparedness Branch has no further concerns,
provided that the state and local agencies have no additional issues regarding the time-critical
removal at the site.
I will distribute our START contractor’s final report covering the monitoring and sampling effort
when it is finalized later this month. It has been a pleasure working with you, and I appreciate all
your dedication to the response/cleanup effort.
Please feel free to reach out if you have additional questions or concerns about this memo.
Sincerely,
Ben Castellana, Ph.D.
On-Scene Coordinator
US EPA Region 9
Superfund Emergency Response
R9-SFD-9-2
(562) 305-0694 cell
-----Original Message-----
From: Ota, Christopher A CIV USN NAVFAC SW SAN CA (USA) <christopher.a.ota.civ@us.navy.mil>
Sent: Tuesday, May 20, 2025 1:04 PM
To: Allen, HarryL <Allen.HarryL@epa.gov>
Cc: Colin M. Cummings (Colin.Cummings@iem.com) <Colin.Cummings@iem.com>; McCoy, Celeste
<McCoy.Celeste@epa.gov>; Castellana, Ben <castellana.ben@epa.gov>
Subject: RE: EHU Calls and Close Out
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