Laserfiche WebLink
Page 1 of 2 <br /> Mike Infurna [EH] <br /> From: Mike Infuma [EH] <br /> Sent: Wednesday, July 28, 2010 2:49 PM <br /> To: 'Rex Smith' <br /> Subject: RE: Beacon 3641, 1210 E Hammer Lane, Stockton, RO#0070 <br /> you do not need regulatory approval to submit a NFAR. If, after an EHD review of an <br /> inadequate or premature NFAR submittal, the RP will be notified of any missing information or <br /> if the EHD does not agree with the NFAR. IF the EHD does not grant NFA, then the RP may <br /> appeal their case to the SWRCB. I will include the information for conducting an appeal in a <br /> formal response/comment letter to your NFAR submittal. <br /> IF you plan on submitting an NFAR, please familiarize yourself with the "TriRegional <br /> Guidelines, Appendix A - Reports", section 6.6 and the checklist also included. Formating <br /> your NFAR on Section 6.6 will significantly expedite EHD's review of the NFAR by insuring ALL <br /> required items are included, thereby reducing EHDs research time to gather the data. <br /> of particular interests for sites submitting NFARs is the inclusion of a TIME estimate for gw to <br /> reach WQOs. Narrative and a graph of concentrations over time for each COG should be <br /> included in the NFAR. The SWRCB has determined that a 'reasonable' time to WQOs for <br /> each COC can qualify a site for no further action. it's the 'reasonable' that is open to numerical <br /> interpretation. Support any and all conclusions for times that could be considered excessive. <br /> Sites where RPs/consultants have concluded that effective remediation has been completed <br /> should anticipate the need to confirm the status/amount of residual mass left in the gw and soil <br /> by comparing 'pre-remedial' concentrations to 'post-remedial' concentrations. IF soil data is <br /> NOT available from the period during or since the remedial effort has been active, then it may <br /> not be possible to accurately estimate the current residual mass in the soil. Concentrations <br /> of the CDCs proposed to be left in place must be quantified. Please ensure this data is <br /> included in the NFAR. <br /> WHere RPs cannot support soil residual mass estimates, the EHD recommends 'confirmation <br /> soil sampling' be conducted to obtain the most current soil concentrations. A work plan should <br /> be submitted. <br /> please advise the EHD of your intentions. <br /> Mike Infurna, <br /> SJCEHD <br /> From: Rex Smith [ma iIto:RSmith@horizonenvironmenta1.net] <br /> Sent: Wednesday, July 28, 2010 2:20 PM <br /> To: Mike Infurna [EH] <br /> Cc: Sexton, Tom; Gary Barker <br /> Subject: Beacon 3641, 1210 E Hammer Lane, Stockton, RO# 0070 <br /> 7/28/2010 <br />