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III . PROBLEM DEFINITION PLAN <br /> There is common agreement between Marley , the DOHS and the Board <br /> on several points regarding the Stockton site. All agree that <br /> Stockton operations have used hazardous or toxic substances , <br /> including chromium, copper and arsenic compounds in its various <br /> production processes and that preliminary water and soils data <br /> indicate some existing contamination of surface and ground waters <br /> I and the underlying soil profiles. A major oversight in the <br /> Marley CAP was to assume that the remedy of the alleged problems <br /> could be addressed without further definition of the areal and <br /> vertical extent of contamination on the property and beyond the <br /> plant boundaries. These deficiencies were correctly addressed by <br /> both the DOHS and the Board review comments. <br /> Marley is in complete concurrence with both the DOHS and the <br /> Board on the need for additional problem definition <br /> 1 investigations prior to committing to a specific, detailed <br /> L remedial action plan. Accordingly, Marley proposes to develop a <br /> phased definitional program to obtain this much - needed <br /> information and is in a position to commit to a time schedule to <br /> obtain such information , upon concurrence by the respective <br /> regulatory agencies. <br /> The problem definition program being proposed is broken into <br /> three areas of discussion reflecting what we conceive to be the <br /> I 6 <br /> I <br />