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Cherokee/Delta Truck (former) page 2 <br /> 3535 Cherokee Lane, Stockton. <br /> The removal, transport, and disposal of up to 2,600 tons of impacted soil must have the <br /> estimated costs for the work included in order for EHD to evaluate the plan. Additionally, the <br /> cost and schedule for the Ozone system installation and operation must also be evaluated by <br /> EHD before an FRP can be approved. <br /> The Central Valley Region Water Quality Control Board (CVRWQCB) has recently made <br /> changes in their process of approving injection to ground water. Due to the potential reaction of <br /> some naturally occurring metals in the subsurface with Ozone injection, additional requirements <br /> have been established to evaluate this concern and determine whether Waste Discharge <br /> Requirements (WDR) are needed. Please contact Mr. James Barton of the CVRWQCB to <br /> ascertain the requirements for evaluation of a WDR permit. EHD cannot approve a FRP that <br /> proposes Ozone injection without this evaluation. <br /> A FRP cannot be approved until costs for the proposed remedial alternatives are presented. In <br /> order to prepare a final remedial action plan there must be a complete understanding of the <br /> contaminant mass impact to individual zones previously identified. <br /> The FRP is not approved as written. The lateral and vertical extent of the contamination <br /> including the MtBE and DCA previously noted must be addressed. When the contaminant <br /> plume mass, the interaction of the multiple permeable zones and the extent, and migration <br /> potential of the contaminants are understood, a FRP that includes a cost effective comparison <br /> of remedial alternatives, may be prepared and submitted to EHD. <br /> Please review the details included in EHD correspondence dated October 9, 2001 and <br /> incorporate the requirements into your next phase of work. EHD suggests a Site Conceptual <br /> Model be constructed for this site utilizing all available data collected so far. Areas where <br /> delineation interpretations and conclusions are drawn without data to support them, should have <br /> investigation proposals of the areas included in the next work plan submitted to EHD. <br /> Please address your submittals to Michael Infurna and you may contact him at (209) 468- <br /> 3454with any questions you may have. <br /> Donna Heran, REHS <br /> Director, Environ ental Health Division <br /> Michael J. Infurna, Senior REHS Margar�agodo, REHS <br /> Site Mitigation-LOP Unit IV Supervisor <br /> MI/ <br /> c: AGE — Paul Dobson, 837 Shaw Rd, Stockton. <br /> c: CVRWQCB—James L. Barton, Sacramento. <br /> c: SWRCB-CUF— Mark Owens, Sacramento. <br />