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Mr. Robert Brod -2- 21 July 2011 <br /> Comments <br /> 1. In the Soil Workplan, storm drain inlets and monitoring wells are identified within <br /> areas targeted for excavation. Storm drains, which lead to an on-site lined pond, will <br /> be protected from receiving sediments pursuant to the Stormwater Pollution <br /> Protection Plan. <br /> 2. Monitoring wells within an excavation may need to be destroyed. Any well <br /> destruction must comply with a Well Destruction Workplan approved by Central <br /> Valley Water Board staff and San Joaquin County Environmental Health <br /> Department. To facilitate timely well destruction, John Deere may submit the well <br /> destruction workplans for approval in advance of the excavation work. <br /> 3. John Deere needs to provide safe access for the tenant of the warehouse on the <br /> 1.5-acre parcel during excavation work. <br /> 4. The Soil Workplan proposes to verify fill soil to be clean using the analyses and <br /> frequency described in California Department of Toxic Substances Control's <br /> October 2001 Information Advisory- Clean Imported Fill Material. Central Valley <br /> Water Board staff concur with this approach. John Deere shall include source <br /> information and analytical data for the fill material in the Site Completion Report. <br /> Conditional Concurrence <br /> Central Valley Water Board staff concur with the Soil Workplan on the condition that: <br /> • Before excavated soil is used as a nitrogen amendment, John Deere will provide <br /> Central Valley Water Board staff with calculations showing that the applied nitrogen <br /> is within the uptake capacity of the target crop within a single growing season. <br /> • Excavated soil shall be placed on a barrier that prevents migration of contaminants <br /> to underlying soil. <br /> • Soil stockpiles shall be covered when not in use. Covering may consist of a tackifies <br /> to prevent wind-blown transmission. Stockpiles shall be covered with impermeable <br /> material if a rain event exceeding 0.25 inches is predicted. Stormwater controls shall <br /> be in place prior to a rain event. <br /> • Characterization of the fill material shall be included in the Site Completion Report. <br /> • John Deere shall notify Central Valley Water Board staff when an excavation <br /> schedule has been secured. <br /> According to the schedule proposed in the Soil Work Plan, ERM intends to begin <br /> excavation work during August 2011, and submit a Site Completion Report by 1 January <br /> 2012. Central Valley Water Board staff appreciate John Deere's intent to remove <br /> California Environmental Protection Agency <br /> r"'�ecyded Paper <br />