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Project No. 014-13157 Page No. 3 Permitting Since the work is considered a "remedial excavation," oversight is required from either the California Regional Water Quality Control Board — Central Valley Region (RWQCB), State Department of Toxic Substances Control (DTSC) or the SJCEHD. According to the SJCEHD, they have a Voluntary Cleanup Agreement (VCA) that can be entered into to provide oversight and approval of the remedial excavation work. Before the SJCEHD can accept the VCA, they must wait 10 days for either the RWQCB or the DTSC to claim oversight, which is not expected. The significant advantage with regulatory oversight is that the agency will issue a No Further Action or some other type of letter that closes the investigation. In addition to the oversight required by one (1) of the agencies listed above, an excavation permit application must be prepared and submitted to the City of Stockton Permit Center (SPC). An additional requirement from the SPC is that a geotechnical report must be prepared prior to their issuing the excavation permit. The geotechnical investigation will include one (1) soil boring to 10 feet bgs. Testing will include moisture density tests; a geotechnical letter report will be submitted to the SPC. According to the San Joaquin Valley Air Pollution Control District (SJVAPCD), a permit for the excavation work is not required from the SJVAPCD. Site Preparation A Site Health & Safety Plan (SHSP) will be updated and will accompany the field activities to be conducted at the site. The SHSP will identify potential safety hazards to personnel working at the site. A geophysical subcontractor will be used to clear the proposed excavation area of subsurface utilities. The proposed excavation area will be marked in advance and we will notify USA North, as required, so the member utility companies can mark their facilities within pertinent public rights- of-way and utility easements prior to our proceeding with the excavation program proposed herein. Excavation Excavation activities will be conducted by using a backhoe or mini-excavator to remove hydrocarbon-impacted soil from the area of composite sample S26, S27, S28. Based on the KRAZAN & ASSOCIATES, INC. With Offices Serving the Western United States 014-13157 2014-3-28 WP for Excavation_Wilson Way Stockton FINAL