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Report of Findings—Phase H Soil anu groundwater Assessment Page 8 Teixeira-Souza Dairy February 1,2007 WKA No. 6504.45 an MCL for nitrates, as previously discussed. Although the WDR also requires submittal of a Closure Plan prior to and a Closure Report after cessation of dairy operations, the WDR is currently considered tentative and may be refined before finalized. WKA contacted Mr. Michael Huggins, Confined Animal Facility Program Manager for the SJCEHD,to discuss dairy closure requirements and agency criteria for evaluating residual impacts to soil and groundwater quality. Mr. Huggins informed WKA that the SJCEHD currently does not have formal closure criteria for dairies, with the exception of removing all related surface features and wastes, along with excavating and removing visually affected soil beneath previous livestock areas and wastewater ponds. Mr. Huggins also stressed the necessity to identify and remove buried animal remains that may pose a health exposure risk as part of future land development. Mr. Huggins referred WKA to the RWQCB's Confined Animal Facilities Unit for further information on evaluating the significance of remaining soil and groundwater conditions after dairy closure activities. According to Mr. David Sholes of the RWQCB's Confined Animal Facilities Unit, there are currently no regulatory criteria defining allowable limits for nitrogen, phosphorous, and potassium related compounds in soil for the protection of groundwater quality. Upon discussing the results of this assessment with Mr. Sholes, it was his recommendation that depending on the planned future use of the property, elevated nitrogen-affected soils be excavated and removed to the maximum extent that is practically feasible as a measure of source reduction to minimize the potential for future methane generation and lingering impacts to groundwater quality. WKA then contacted Ms. Charlene Herbst, the RWQCB's Confined Animal Facility Program Director to discuss the results of this assessment and to clarify specifics of the RWQCB's tentative WDR. Ms. Herbst informed WKA that requirements in the WDR are intended to provide the RWQCB with a mechanism to collect and evaluate assessment data so that cleanup goals can be refined in the future. Until the WDR is finalized, Ms. Herbst's recommendation for dairy closures was to remove all visible and reasonable accessible waste materials, including wastewater pond areas, and reduce surface water runoff of dairy related constituents. Ms. Herbst stated that there is currently no general RWQCB requirement for groundwater extraction at active or former dairies to reduce nitrates and nitrogen related compounds in groundwater. Ms. Herbst suggested that establishing a setback requirement or deed restriction would be a prudent administrative measure to prevent the future use of groundwater immediately beneath or adjacent to previous dairy operations.