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1 <br />Field, Cheryl [EHD] <br />From:McClellon, Robert [EHD] <br />Sent:Thursday, April 21, 2022 2:49 PM <br />To:Field, Cheryl [EHD] <br />Subject:FW: Schedule for excavation, 500 East Louise Avenue (Waste Unit 1) <br /> <br /> <br />From: Djuth, Gerald@Waterboards <Gerald.Djuth@waterboards.ca.gov> <br />Sent: Thursday, March 14, 2019 10:52 AM <br />To: Robert Marty <rmarty@advgeoenv.com>; Palmer, Ann@Waterboards <Ann.Palmer@waterboards.ca.gov>; Linda <br />Turkatte [EH] <LTurkatte@sjcehd.com> <br />Cc: Robert McClellon [EH] <RMcClellon@sjcehd.com>; Brian W. Millman <bmillman@advgeoenv.com>; Dana Parry <br /><danap@reynoldsandbrown.com>; Black, Stewart@Waterboards <Stewart.Black@Waterboards.ca.gov> <br />Subject: RE: Schedule for excavation, 500 East Louise Avenue (Waste Unit 1) <br /> <br />Robert – The planned excavation of the WU-1 waste materials residing on Parcel A, which is residual waste <br />from the Parcel B excavation recently completed, was first proposed in your 12/21/18 Work Plan Addendum <br />to the Excavation and Material Management Plan prepared by Brusca Associates, Inc. <br /> <br />On 1/22/19, Linda Turkette from San Joaquin County Environmental Health Department provided comments <br />on the Work Plan Addendum. <br /> <br />On 2/22/19 you submitted the WU1 Clean Closure Plan and Work Plan Addendum to address Ms. Turkette’s <br />comments. <br /> <br />Regional Water Board staff have been communicating regularly with AGE staff regarding the work currently in <br />process to investigate the adjoining CoGen facility. Furthermore, we have communicated with AGE staff on <br />the diesel cleanup project on the former Pilkington property. <br /> <br />At no time since submittal of the 12/21 Work Plan Addendum or the 2/22 Clean Closure Plan was it <br />communicated to Regional Water Board staff that there was an urgent need to complete review of the Clean <br />Closure Plan due to scheduled excavation activities. Regional Board staff first became aware of the <br />scheduled excavation while in the field observing the CoGen facility drilling on 12 March. In my telephone <br />conversation with Dana Parry on 13 March, I learned that these activities were scheduled over two weeks ago, <br />with no attempt to inform Regional Water Board staff, even though we were communicating regularly with your <br />staff on other issues (i.e., CoGen and Diesel spill). <br /> <br />Had the urgency been communicated, we could have scheduled our time appropriately. However, at this late <br />juncture, your work plan is not approved by Regional Board staff. Although we will make our best effort to <br />review the work plan and provide comments prior to the scheduled activities, at the time of this writing, your <br />client is moving forward on his own volition with the possibility that confirmation sampling will need to be <br />repeated and/or additional excavation required in order to received concurrence from the Regional Water <br />Board on Clean Closure. <br /> <br />If you wish to discuss this further, do not hesitate to reply to this email or call me at the number below. <br /> <br /> <br />Gerald Djuth, PE, CEG <br />Chief, Federal and Private Site Cleanup Unit <br />Central Valley Regional Water Quality Control Board