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Site Background Information: Cherokee Truck Stop AGE-NC Project No. 97-0312 Page 5 of 6 impoundment or landfill(ESE, 1991).The additional borings found that landfill material extended to depths of 10 feet and only one boring showed evidence of the paint, ash, wood and concrete debris found in earlier investigations.These results indicated that the landfill did not extend east of the current excavation,however it remained undefined to the west and offsite.In July 1991,the State Water Resources Control Board adopted a resolution (No. 91-63) officially deleting Delta Truck from the TPCA facility list and stating that all TPCA requirements had been met (CVRWQCB, 1991c). Proactive issued a Remediation Plan to the CVRWQCB in August 1991 and requested reclassification of the stockpiled soil through the Department of Toxic Substances Control(DTSC) in a 12 September 1991 application (Proactive, 1991a). Proactive's September 1991 request for reclassification of the soil to nonhazardous was rejected by the DTSC because the required$8,000 in fees were not submitted. In 04 December 1991 correspondence,the DTSC requested additional information from Proactive regarding the reclassification application. Proactive responded to this request on 20 December 1991. DTSC again denied reclassification in May 1992 due to numerous missing items including lack of fees submitted, sampling procedures, and data evaluation. The CVRWQCB issued to Delta Truck a notice of violation of the Cleanup and Abatement Order on 28 October 1991 (CVRWQCB, 1991 d).The remediation plan submitted by Proactive in August of 1991 was not approved because it lacked sufficient detail and was not accompanied by a closure plan.The remediation plan submitted was based on the assumption that the DTSC would determine that the waste was nonhazardous and that the CVRWQCB would determine it was inert. The CVRWQCB stated that because the reclassification issue had not been resolved,Delta Truck should submit closure plans for each potential classification.The CVRWQB requested a written response describing the proposed methods to bring the facility into compliance with cleanup and abatement action and time schedule. In July 1992, site ownership changed due to foreclosure of the property. ESE was retained by the new owners (Cecchini, Cecchini, and Giovannoni)in August 1992. ESE characterized the existing 12,000-cubic yard soil stockpile in accordance with DTSC requirements for stockpile sampling and evaluated the data to determine if reclassification of the stockpiled soil was possible and to determine future action for the site (ESE, 1993a). A stockpile classification report was completed by ESE in August of 1993 and submitted to the CVRWQCB. Based on this report the CVRWQCB advised ESE to seek reclassification of the soil from the DTSC. In October 1993, the stockpile classification report was submitted to the DTSC -Alternative Technology Division. In a meeting December 1993 with the Alternative Technology Division,Mr. Chris Marxen recommended: 1)not reclassifying the soil because of new additional requirements, Advanced GeoEnvironmental,Inc.