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FROM 1997,05-15 12:29 #177 P.03/03 <br /> MAY: -15' 97(THU1 11: I? UNOCCERT NORTH RE TEL:51Cr7 :309 <br /> P. 003 <br /> Pursuant to Article 11 of the California Code of Regulations (CCR) Section 272-2. <br /> (b)(3) excavation and disposal of contaminated soil is considered an interim <br /> remedial action. Subsequent to the overexcavation you were directed to complete <br /> the assessment. Based on the results of the'assessment you were directed to <br /> perform a feasibility study. Your pilot VES system data partly fulfills CCR 2725 <br /> (f)(2) which states that the feasibility study shall evaluate two alternatives for <br /> restoring beneficial uses of groundwater. Once the assessment and the feasibility <br /> study are complete you may submit the Corrective Action Plan (CAP) CCR 2725. <br /> The CAP shall Include numerical objectives in the CVRWQCB basin plan, 1 ppb <br /> for benzene, to be used to establish target cleanup values to restore current or <br /> potential beneficial uses of water. <br /> The current PHSIEHD directive recommends that you perform a well surrey to <br /> complete your assessment and to evaluate natural attenuation, as a second <br /> a3temative, to complete your feasibility study. If the result of the feasibility study is <br /> that natural attenuation is the most cost effective alternative then that alternative <br /> should be recommended for Implementation in your CAP. <br /> Closure of this site as a low risk groundwater site may occur if site specific data I <br /> demonstrating natural attenuation (in addition to the stable and decllning trends in <br /> the monitoring wells) can be produced, and a rational to explain that natural <br /> attenuation will restore the beneficial use of the groundwater based on the basin <br /> plan. Closure of this sits is not appropriate at this time. <br /> For additional information please contact Steven.' Sasson at (209).48&3489. <br /> Donna Heran, REHS, Director <br /> Environmental Health Division <br /> n <br /> SteveInAO , tn �rEHS Marga Lagorio, HS <br /> Site Mitigation Unit Supervisor <br /> cc: Elizabeth Thayer, CVRWQCB <br /> 4 <br /> cc: James Brathovde, CVRWQCB <br /> If <br />