LSA Response to Geosyntec Report
CARLSBAD
CLOVIS
IRVINE
LOS ANGELES
PALM SPRINGS
POINT RICHMOND
RIVERSIDE
ROSEVILLE
SAN LUIS OBISPO
MEMORANDUM
D ATE:
June 17, 2024
T O:
Larry Ryan, RJM Design Group
F ROM:
Deborah Pracilio, Principal
S UBJECT:
Responses to City of Irvine Technical Memorandum Focused Technical Review and
Feasibility Assessment of the Proposed Veterans Cemetery Gypsum Canyon Site,
Anaheim, California
LSA has reviewed the Focused Technical Review and Feasibility Assessment of the Proposed
Veterans Cemetery Gypsum Canyon Site (May 24, 2024) prepared by Geosyntec. We have
specifically reviewed the comments related to hazardous materials, outlined in the technical review
memo, as they relate to the Phase I Environmental Site Assessment (ESA) prepared for the proposed
project by Ninyo and Moore (December 2023). We have not reviewed the Phase I ESA, prepared by
Aptim, referenced in the comments. Our response to these comments is provided below:
Environmental Comments:
The latest Phase 1 Environmental Site Assessment (ESA) \[Aptim, 2023\] done for the Site contains
several inconsistencies, the major ones are:
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used for mining purposes are still present and are visible within the Site and were described in the
same document.
The historical McDonnell Douglas/Astropower facility used for rocket fuel testing between 1961 and
1991 at the Site, which is mentioned in Appendix J of the 2005 EIR No. 331 for the previously
proposed Mountain Park Development Site, is not mentioned in the 2023 Phase 1 ESA. The center of
the rocket fuel testing was located approximately 1 mile south of the mouth of Gypsum Canyon.
Response:
the Phase I ESA prepared for the Addendum acknowledged the presence of the
3210 El Camino Real, Suite 100, Irvine, California 92602 949.553.0666 www.lsa.net
rocket test site and determined that due to its distance from the project site is not a recognized
environmental concern (REC).
The 2023 Phase 1 ESA concludes that no Recognized Environmental Conditions (RECs), no Historical
RECs (HRECs), no Controlled RECs (CRECs), nor petroleum products were encountered within the
Site. The historical McDonnell Douglas/Astropower facility should be considered an HREC, at a
minimum.
Response:
The Phase I ESA prepared in support of the Addendum identified three RECs. The rocket
test site was not identified as an HREC but was acknowledged as a historic activity. Not identifying
the rocket test site as a HREC does not affect the conclusions of the Phase I ESA prepared for the
Addendum, due to the distance of the rocket test site from the project site.
The Phase 1 ESA \[Aptim, 2023\] concludes that a Phase 2 ESA is not warranted. This is questionable,
since it is still unclear if historical impacts from Site past industrial use have been fully mitigated to
Response:
Preparation of a Phase 2 ESA, prior to issuance of grading permits, has been identified in
the Addendum and associated Mitigation Measure MM) 10-1 to confirm presence/absence of the
identified RECs within the project site.
Furthermore, regulatory requirements have changed since the 2005 EIR, probably resulting in more
analyses, regulatory negotiations, and potentially costly environmental remediation if the Site is
developed.
Response: The Phase 2 ESA would identify any residual contamination that exceeds current
regulatory limits and appropriate remedial action identified. Additionally, the Phase 2 ESA may not
identify all residual contamination and contamination could be encountered during construction
activities. A response plan will be prepared prior to issuance of a grading permit to address unknown
contamination encountered during construction. Both conditions are addressed in MM 10-1
identified in the Addendum.
Additional costs associated with the potential extensive environmental remediation work and
additional required analysis necessary to meet current regulatory requirements for the type of
proposed site improvements do not appear to have been included in the final concept plan cost
estimate for the project. While these costs are dependent on several factors such as the extent and
nature of remediation as informed by additional testing and analyses and are difficult to be
quantified at this time, it should be noted that these might add significant costs to the project.
Response: There could be additional costs due to remediation of residual contamination identified as
part of the Phase 2 ESA or unknown contamination encountered during grading activities. The
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amount of any additional remediation costs is unknown at this time but would be informed by the
results of the Phase 2 ESA.
Please contact me if you have any questions regarding the findings presented in this memo.
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