SITE INFORMATION AND CORRESPONDENCE

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Pursuant to Article 11 of the California Code of Regulations (CCR) Section 2722 (b)(3) excavation and disposal of contaminated soil is considered an interim I remedial action. Subsequent to the overexcavation you were directed to complete the assessment. Based on the results of the assessment you were directed to perform a feasibility study. Your pilot VES system data partly fulfills CCR 2725 (f)(2) which states that the feasibility study shall evaluate two alternatives for restoring beneficial uses of groundwater. Once the assessment and the feasibility study are complete you may submit the Corrective Action Plan (CAP) CCR 2726. The CAP shall include numerical objectives in the CVRWQCB basin plan, 1 ppb for benzene, to be used to establish target cleanup values to restore current or potential beneficial uses of water. The current PHSIEHD directive recommends that you perform a well survey to complete your assessment and to evaluate natural attenuation, as a second alternative, to complete your feasibility study. If the result of the feasibility study is ' that natural attenuation is the most cost effective alternative then that alternative should be recommended for implementation in your CAP. Closure of this site as a low risk groundwater site may occur if site specific data demonstrating natural attenuation (in addition to the stable and declining trends in the monitoring wells) can be produced, and.a rational to explain that natural attenuation will restore the beneficial use of the groundwater based on the basin plan. Closure of this site is not appropriate at this time. For additional information please contact Steven Sasson at (209) 468-3459. i Donna Heran, REHS, Director Environmental Health Division i n 3 Steven SaAon, enior EHS Margam LLaagorio, rHS Site Mitigation Unit Supervisor cc: Elizabeth Thayer, CVRWQCB cc: James Brathovde, CVRWQCB