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may zuuy <br />Based on the historical data and trends, the Central. Valley Regional Water Board <br />concurs with the recommendations for revising the MRP, however a more appropriate <br />time to revise the MRP will occur following the installation of the deeper groundwater <br />monitoring wells and the receipt of the initial data from those new wells. <br />Requirements for an NFA for Soil <br />7. During an onsite meeting on 23 March 2009, JTF verbally recommended no further <br />action (NFA) for soil. Prior to approving an NFA for site soil, JTF must demonstrate: <br />a. That the cleanup action plan has been properly implemented for soil. <br />b. That all cleanup action plan objectives have been met for the soil. <br />C. That the soil at the site does not pose a threat to human health and the <br />environment and to the groundwater. The Central Valley Regional Water Board <br />considers California Human Health Screening Levels (CHHSLs) to screen sites <br />for potential human health concerns. If CHHSLs are not available, PRG's can be <br />used in lieu of CHHSLs. In September 2008, EPA updated the screening levels. <br />The updated Region 9 PRG Table (now called Regional Screening Level (RSL) <br />table) should be used in the same way that the PRG's have been used in the <br />past. Both a user's guide, and new tables are provided at EPA's website at <br />http://www.epa.gov/region09/waste/sfund/prg/rsl-table.html <br />8. Based on the items discussed above, JTF needs to submit a request for a NFA <br />determination for soil. The request for NFA shall include a summary of major events <br />and accomplishments during the investigation/remediation process, including the extent <br />possible: <br />a. The cause of the release if known; <br />b. The estimated amount and type of product released; and <br />C. The estimated amount of product recovered. <br />9. Documentation: Cleanup completion documentation shall include a demonstration and <br />analysis that cleanup objectives for the site have been met as outlined. JTF shall also <br />submit all documents (permits, certificates, approvals, etc) relating to the transportation <br />and disposal of wastes from the site. <br />Summary <br />The Regional Water Board does not concur with JTF's recommendation to revise the MRP at <br />this time, but will consider revising the MRP once further vertical delineation of COC's in deep <br />groundwater (approximately 50 feet bgs) has occurred. A work plan describing this scope of <br />work is due by 10 July 2009. JTF may submit a request to the Central Valley Regional Water <br />Board for consideration of whether no further action is needed regarding soils at the site. <br />