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Mr. Steve Pinkerton <br /> April 12, 2001 <br /> Page 2 <br /> DTSC has evaluated the RAO proposed for total petroleum hydrocarbons (TPH). Since <br /> fractions of TPH differ in mobility, DTSC recommends RAOs for TPH as motor oil at <br /> 1,000 ppm and as diesel at 100 ppm. The Regional Water Quality Control Board <br /> concurs that these values should be protective to the waters of the State and are <br /> acceptable RAOs. <br /> In order to demonstrate that removal of the constitutes of concern has occurred, post <br /> excavation sampling will be required. If the sampling indicates that the values exceed <br /> the RAOs, additional excavation will be necessary until the objectives have been met. <br /> Based on the RAOs and using a plot map, or other maps, the soil areas and depths to <br /> be excavated need identification. DTSC anticipates that it will be necessary to <br /> reevaluate the cost estimates for excavation, transportation, and disposal of the soil to <br /> meet the revised RAOs. DTSC wants to know which disposal facilities could be used <br /> and a general period of time for completing the activities. These evaluations must be <br /> included in the Feasibility Study or its Addendum. <br /> The FS proposes to use a deed restriction to control unacceptable land uses. DTSC <br /> requests that the FS provide a brief description of the type of restriction that will be <br /> included in the land use covenant. Specifically, the description needs to include <br /> prohibited uses including residences, hospitals, schools, and day care centers, and the <br /> need for a soil management plan detailing actions to be taken if any contaminated soil <br /> needs to be disturbed. Enclosed is a copy of DTSC's policy and procedure (without <br /> referenced attachments) for land use covenants. In addition, it is necessary to require <br /> the land owners to record the land use covenant, therefore, with any property not <br /> owned by the City, DTSC would like affirmation that such parties would accept a land <br /> use restriction. <br /> Once these comments are adequately addressed, DTSC will be able to provide an <br /> approval letter for the Remedial Investigation/Feasibility Study reports. <br /> Sincerely, Q <br /> rte'. <br /> �Y <br /> Tga�n Cambridge, Chief <br /> Expedited Remedial Action Program Unit <br /> Enclosure <br /> cc's: See next page. <br />