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N � California Regional Water Quality Control Board <br /> R � Central Valley Region <br /> Karl E.Longley,ScD,P.E.,Chair (@ <br /> Linda Adams Sacramento Main Office Arnold <br /> Secretaryfor 11020 Sun Center Drive#200,Rancho Cordova,California 95670-6114 Schwarzenegger <br /> Environmental Phone(916)464-3291 •FAX(916)4644645 Governor <br /> Protection http://www.waterbouds.ca.gov/centralvality <br /> 2IFC NvE <br /> JUL 2 3 2008 <br /> 21 July 2008 <br /> ENVIRONh?ENTHEALTH <br /> PERMIT/SERVICES <br /> Nader Shareghi, P.E. Eric Teed-Bose <br /> Mountain House CSD Trimark Communities <br /> 230 S. Sterling Drive, Suite 100 3120 Tracy Boulevard, Suite A <br /> Mountain House, CA 95391 Tracy, CA 95376 <br /> WORKPLAN REVIEW, SITE CLOSURE CHARACTERIZATION WORK PLAN, MOUNTAIN <br /> HOUSE CSD AND TRIMARK COMMUNITIES, SAN JOAQUIN COUNTY, SAN JOAQUIN <br /> COUNTY <br /> Staff has reviewed the 17 March 2008 Site Closure Characterization Work Plan Reclamation <br /> Area 1, Reservoirs 1A, 1B, and 2, prepared by Condor Earth Technologies. The workplan <br /> was prepared to describe investigation of sludge and soil quality in preparation of <br /> redevelopment of the area formally used for wastewater storage and application. The <br /> workplan does not adequately describe how the ponds will be decommissioned, liners <br /> removed, and screening criteria that will be used to determine if additional investigation is <br /> warranted. Please address the following comments in a revised workplan: <br /> 1. Section 1.0 states, 'The primary goal of the closure process is to obtain approval to <br /> remove the existing effluent storage reservoirs and provide for the proposed <br /> unrestricted reuse of the site based on sensitive land use criteria." Regional Water <br /> Board staff will guide you though the decommissioning of the storage reservoirs. The <br /> unrestricted reuse must be obtained through the All Appropriate Inquiry protocol, its <br /> associated review process, and local government land use and zoning policies. <br /> 2. Section 1.0 describes Figure 3 as presenting historic soil sample locations. Figure 3 <br /> does not depict this information. If historic soil quality data is available, it should be <br /> presented and discussed. <br /> 3. Section 3.1 discusses disposal of sludge but does not describe what is actually <br /> planned. Please determine how the sludge will be disposed and provide that <br /> information. This information will be critical in determining the full suite of analytical <br /> methods. For example, the disposal facility may have different analytical requirements <br /> than are listed in Waste Discharge Requirements (WDRs) Order No. 98-109. <br /> 4. Section 3.1 references the October 2006 Mountain House Wastewater Treatment Plant <br /> Operations and Maintenance Manual (O&M Manual) but staffs review of the sludge <br /> handling description in the O&M Manual indicates it is not descriptive enough to <br /> determine what will happen to the sludge or if the procedures would be protective of <br /> groundwater quality. Presumably, the reservoir sludge would be combined with sludge <br /> generated in the wastewater treatment process. But there is no description of how long <br /> California Environmental Protection Agency <br /> ea Recycled Paper <br />