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South San Joaquin Irrigation Distnct DRAFT Lead Assessment&Soil Relocation Work Plan For Discussion Purposes Only. Do Not Distribute July 5, 2017 On February 1, 2017, the SJCEHD issued a Waste Discharge/Spill Response Notice ("Notice") to Abate to SSJID. Refer to Appendix A. The Notice states that lead from the ESC is polluting nearby orchards and the Canal and lists the following corrective actions: • Immediately contain, clean-up and dispose of waste at an authorized, permitted location. Ensure that cleanup personnel possess adequate training. • Investigate and abate contamination under the oversight of the appropriate lead agency • Submit copies of hazardous waste manifests/disposal records to the SJCEHD within 30 days. On February 27, 2017, representatives of SSJID and SJCEHD met to present a Draft Interim Lead Assessment and Abatement Workplan. Because of the need for its customers to receive irrigation water for the upcoming growing season, SSJID expressed the need to deliver water in the canal starting in March and ending in October. Once the irrigation season has ended, assessment and abatement of the lead would commence with the goal of completion prior to the beginning of the 2018 irrigation season. During the meeting, SJCEHD stated that SSJID can participate in the SJCEHD Voluntary Cleanup Program (VCP) to perform assessment and abatement. SJCED supplied the VCP and Service Request forms to SSJID and suggested that SSJID complete and submit the Service Request form so that SJCEHD can review a revised workplan. On March 15, 2017, SSJID sent the completed VCP and Service Request forms to SJCEHD to begin the assessment and abatement workplan review process. On May 16, 2017, representatives of SSJID, ESC and SJCEHD met with staff from the Department of Toxic Substances Control (DTSC) to discuss the project. During the meeting, DTSC stated that soil with lead pellets (which may have concentrations of lead which would qualify it as hazardous substance) could be removed from the canal and placed onto the shooting range. On May 22, 2017, DTSC in an email stated that the "Site" is the area of contamination ("AOC') and that the AOC is the property where the hazardous substance has been deposited and any adjacent areas that have been contaminated in the same manner. DTSC further stated that the irrigation canal where lead pellets from shot guns have landed is part of the AOC just as much as the gun range. DTSC went on to state that if soil was classified as exhibiting a hazardous waste characteristic, such soil may be managed on-Site within the AOC without triggering DTSC hazardous waste management requirements, including permitting, closure, post-closure, or compliance with land disposal restrictions. DTSC concluded that contaminated media may be moved or consolidated within an AOC, treated in situ, or left in place. The approximate area of where lead pellets are found is shown in Figures 3 and 4. Page 6 Blankinship & Associates , Inc .