SITE INFORMATION AND CORRESPONDENCE

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D&D Properties LLC -2 - 23 July 2010 Former Tiger Lines Truck Yato . The Stockpile Remediation Work Plan proposes to conduct confirmation sampling by collecting about 56 soil samples throughout the stockpile. The samples will be submitted for laboratory analysis where they will be composited 4 to 1 and tested for TPHd by EPA Method 8015M. MARCOR calculated a soil cleanup goal of 100 mg/kg using the Designated Level Methodology for Waste Classification and Cleanup Level Determination (RWQCB June 1989). The 95 h percentile upper confidence level (UCL 95) of confirmation sampling concentrations will be calculated from the analytical results and compared to the cleanup goal to determine compliance with this value. The excavation will then be backfilled with the remediated soil. Our comments are presented below. 1. Central Valley Water Board staff concurs with the remedy proposed for the stockpile. However, the Stockpile Remediation Work Plan requires revision to include (1) further details regarding the existing levels of contamination in the stockpiles and (2) procedures that will be employed to ensure the cleanup will comply with applicable regulatory requirements. The suggested revisions are discussed in the following comments. 2. Table 1 in the 25 February 2010 Source Removal Excavation Report lists the laboratory results of concentrations of the contaminants encountered in the subsurface during the removal action. Please include a copy of the Table in the Stockpile Remediation Work Plan to provide an indication of the baseline concentrations of total petroleum hydrocarbons (TPH) in the stockpile. 3. Dischargers whose projects disturb one or more acres of soil are required to obtain coverage under the new General Permit for Storm Water Discharges Associated with Construction and Land Disturbance Activities Order No. 2009-0009-DWQ (Construction General Permit). The new Construction General Permit is a risk-based permit and requires the development and implementation of a Storm Water Pollution Prevention Plan (SWPPP) in accordance with the appropriate risk level. The SWPPP will include a monitoring program for "non-visible" pollutants and may require effluent monitoring for pH and turbidity based on the project risk level. Details regarding application for coverage under Construction General Permit are available online at http://www.waterboards.ca.gov/water issues/program s/stormwater/constpermits.shtml. Central Valley Water Board Storm Water Section staff can be reached by telephone at (916) 464-4764. 4. The proposed cleanup must also be conducted pursuant to the regulations of the San Joaquin Valley Air Pollution Control District (SJVAPCD). This agency has prepared Rule 4651 to regulate Soil Decontamination Operations. Details regarding Rule 4651 are available on the internet at http://www.valleyair.org/rules/1 ruleslist htm. Rule 4651 may provide an exemption for the proposed operation, but the SJVAPCD must be contacted to ensure applicability.