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0 0 <br /> • Title 23 CCR, Division 3, Chapter 15, Article 5 and Articles 8-9 are potentially <br /> applicable to capping. These regulations provide detailed requirements for <br /> monitoring of water quality. <br /> 15) The RAW should identify that after the remediation is completed, a Construction <br /> Implementation / Closure Report will be prepared and submitted to DTSC for approval <br /> of completed remediation. The report will include, but not limited to: a description of <br /> field activities completed and deviation from the RAW, analytical laboratory <br /> confirmation sampling results, and air monitoring readings. Photos must be included in <br /> the Construction Implementation / Closure Report. <br /> 16) The RAW should state that DTSC will file a notice of exemption from the California <br /> Environmental Quality Act (CEQA)following the RAW's approval. <br /> 17) The RAW must identified all necessary permits (i.e., grading permit) state a copy will <br /> be provided to DTSC three days prior to excavation activities commence. <br /> 18) The RAW should state that prior to starting excavation activities, the impacted soil <br /> should be wetted daily to minimize dust. <br /> 19) As identified in the RAW in section 13.0, a cap will be needed to prevent rain infiltration <br /> on the soil contamination. The RAW proposes an Operation and Maintenance Plan as <br /> a component of the proposed remedy. Based on the phone conversations with My Ellis <br /> Cecchini and your consultant (Advanced Geo Environmental, Inc), a cap might not be <br /> required for protection of the groundwater if the contamination does not pose a threat <br /> to the groundwater. Please refer to comment #4 for more information. If a cap is not <br /> required as a component to the remedy, then an Operation and Maintenance Plan will <br /> not be needed. <br /> 20) Prior to approving the RAW for a 30-day public comment period to allow the public to <br /> review and document and provide comments, a community profile and other <br /> associated public participation activities must be completed. Please contact Mr. <br /> Nathan Schumacher at (916) 255-3650 for additional information regarding public <br /> participation activities. <br /> 21) The stockpile material contains concrete debris which might cause compaction or <br /> infiltration problems if placed in the excavation area. The RAW should discuss if there <br /> are any problems with placing the concrete debris in the excavation area. If there are <br /> problems, the concrete debris needs to be transported off-site to a Class III landfill. <br /> 22) Section 14 in the RAW should state the following: "A land use covenant (LUC) will be <br /> required as a component to the remedy. A LUC will be recorded on the property to <br /> restrict the land use to commercial / industrial activities. The LUC will require a soil <br /> management control including the requirement for a soil management plan. The LUC <br /> will be prepared consistent with DTSC policy and finalized and recorded after physical <br /> remedial measures are implemented and before the site is certified by DTSC as being <br /> remediated. The LUC will run with the land and stay in effect as long as hazardous <br /> Page 4 of 5 <br />