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Universal Forest Products page 2 <br /> 26200 Nowell Rd, Thornton. August 6, 2005 <br /> • This discrepancy with the soil amount must be addressed and approved <br /> by the EHD and the transport documents must be submitted to the EHD <br /> before a request for no further action can be approved. <br /> • The EHD is concerned with a lack of soil analytical data from the three "SB" <br /> borings drilled during February 2005. There is no laboratory data for these <br /> borings between the ground surface and the first sampled point reported at <br /> 25 feet below ground surface (`bgs). In discussions with your consultant, it <br /> - was stated to the EHD that no samples were analyzed for this interval <br /> because your consultant believed the EHD did not require them. The EHD <br /> has checked all -readily available field notes for this phase and could not <br /> document that a waiver to this requirement had been issued. The EHD <br /> cannot complete any review of a no further action request without the site <br /> being fully characterized. Soil analytical data is required from the noted <br /> interval so that an estimate of the residual soil contaminant mass can be <br /> calculated, as required in all no further action reports. The soil vapor work <br /> plan due at the EHD can include a proposal to collect these required soil <br /> samples for laboratory analysis. Please refer to the EHD's October 5, 2005 <br /> correspondence for the constituents to be analyzed for. An adequate <br /> number of borings are to be installed to provide the data to support <br /> conclusions of lateral and vertical extents of the soil plume. <br /> An Environmental Screening Level (ESL) evaluation for soil and a vapor intrusion <br /> hazard evaluation is required in all no further action reports. The information you'll <br /> need to complete this requirement can be found at this attached website page: <br /> • http://www.waterboards.ca-gov/sanfranciscobay/water issues/available docu <br /> ments/ES L_May_2008_web.xis <br /> Your request for no further action is not approved at this time. <br /> i <br /> This decision is subject to appeal to the State Water Resources Control Board <br /> (SWRCB), pursuant to Section 25296.40(x)(1) of the Health and Safety Code <br /> (Thompson-Richter Underground Storage Tank Reform Act -- Senate Bill 562). Please <br /> contact the SWRCB Underground Storage Tank Program at (916) 341-5752 for <br /> information regarding the appeal process. <br /> After the additional data has been collected, and the above noted items have been <br /> satisfactorily addressed, you may submit a revised no further action report to Geotracker <br /> for the EHD to review. Please familiarize yourself with the minimum 'requirements that <br /> are to be included in a no further action request report, as noted in the Tri-Regional <br /> Guidelines on this attached web site, page 21, section 6.6. <br /> • (http://www.waterboards.ca.gov/centraIvaIley/water_issues/underground_storage <br /> tanks/tri-regionals_appendix_a.pdf) <br /> I <br /> 26200 Nowell NFAR deny CML 8-6-08.doc 4 <br /> t <br />