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30 August 2011 <br /> AGE-NC Project No. 97-0312 <br /> Page 2 of 3 <br /> This recommended remedial undertaking was not intended to be an iterative event followed <br /> by successive additional iterations; the recommended course of remedial activity, rather <br /> proposed what cost-effective action could be done, to mitigate the practically recoverable <br /> fraction of residual mass. Mass will remain following this proposed undertaking, though in <br /> lower concentration than what presently exists. Remedial action over and above that <br /> previously described and directed, will not yield substantial additional benefits. <br /> During the first quarter of 2011, ground water monitoring determined hydrocarbon impact <br /> to ground waterwas declining. Given this,sampling and analysis of ground water following <br /> cessation of remedial activities will also provide no practical benefit. <br /> USTCF DECISIONS <br /> The 2008 the Underground Storage Tank Cleanup Fund (USTCF) five-year review <br /> summary of site conditions noted that active remediation had not been conducted in the <br /> site history and recommended a directive to assess active remediation,that would achieve <br /> Water Quality Objectives in a reasonable period of time without active remediation. Eight <br /> drinking water wells were noted to be within one-half mile of the site. <br /> The 2010 the USTCF five-year review summary of the same site conditions,recommended <br /> the EHD review the site for closure. The State Water Resource Control Board has <br /> determined the CHEROKEE TRUCK STOP claim costs not associated with site closure, <br /> will not be reimbursable. <br /> Through EHD letter, dated 26 October 2010, your office acknowledged without sustained <br /> SVE recovery rates and a determination that "no cost-effective remedial technology <br /> suitable to address the residual soil mass",the EHD will investigate the potential for a low- <br /> risk closure for the site. <br /> The State Water Resource Control Board has determined cost associated with other <br /> activities would not be reimbursed and site conditions warrant no further action. <br /> PROPOSED ACTION <br /> Prior to any final phase of remedial activity designed to remove what residual mass, that <br /> can be practically removed/destroyed, AGE requests a cessation of correct action <br /> activities. <br />