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Marley Cooling Tower Company -2- 22 July 1986 (Mitigation Activities Work Plan) Pages 4 and 5; South Yard Runoff and Drainage Ditches - The proposed soil sampling program appears to be adequate to define the extent of contamination present in the shallow soils lining the South Yard drainage ditches. However, MCTC should provide additional information regarding any activities which involved the fabrication and storage of treated wood products on the South Yard (i.e. , type of activity, how long activity was conducted, approximate quantity of materials involved, and location of activity). If results of the soil sampling program indicate elevated levels of wood treatment chemicals then it is likely that runoff from the South Yard contained concentrations in excess of NPDES permit limits. Therefore, MCTC should consider remediation of the I contaminated areas on the South Yard prior to start of the next rainy season. j Soil Contamination - MCTC is considering no future actions in regard to the soil contamination associated with the retort pit area. Present soil analyses has identified this area as a source of contamination. However, additional analysis C may be necessary to characterize the soils underlying this area for the purpose of adequately evaluating the remedial alternatives being considered for the mitigation plan. Pond Closure Page 5; Hydrogeologic Assessment Report (HAR) - It is the preliminary interpretation of the Board staff that all persons who have discharged or are presently discharging liquid hazardous wastes into a surface impoundment must submit a HAR if they intend to either continue operation of the impoundment or I close the impoundment. However, since this is a policy issue which will affect a number of sites in our region the Board will address this issue separately from the comments pertaining to this submittal . Interim Measures Page 5; MCTC's present NPDES permit covers only the treatment and discharge of contaminated stormwater. If MCTC decides to expand their treatment operations to include contaminated ground water or request a relaxation of their discharge limits they will be required to submit a new application and any support documents necessary for the Board to consider revision of their present permit. Mitigation Plan The presented outline is comprehensive and should provide adequate guidance for MCTC to develop their mitigation plan (MP). However, the overall work plan does not identify all the investigation activities necessary to adequately evaluate the remedial alternatives which will be considered in the MP. Therefore, MCTC should include in their work plan all activities needed to provide the support information that will be used to consider each of the remedial I alternatives.