SITE INFORMATION AND CORRESPONDENCE_FILE 2

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Chapter 15: Site Assessment Pre-Field Work Considerations September 2012 There are several tasks to consider prior to beginning field work, such as preparing a work plan, acquiring appropriate permits,etc.The following is a discussion of important pre-field considerations. Please note that this is not intended to be all-inclusive, as each LUPT site is unique and has unique requirements. It is important for RPs and consultants to work with the regulatory agency overseeing the site assessment to ensure that pre-field considerations have been addressed prior to mobilization for field work. Work Plan Submittal of a work plan is required prior to conducting field activities associated with a LUFT site assessment, as discussed in the Work Plan chapter of this Manual. Regulatory Requirements and Permits It is important to identify the regulatory requirements prior to performing an investigation at a LUFT site. Regulatory permits may be required prior to site assessment (and cleanup phases). Contact the applicable regulatory agency(i.e.,federal,state,county,and municipality)for details.This section describes typical regulatory permits that may be required for a LUFT investigation. Additional information may also be available in guidance documents provided by the regulatory agency. The RP is required to obtain the proper permits in order to perform work. Permits may be required for ground disturbance activities such as advancing borings(including CPT points)and constructing and destroying monitoring wells. Depending on the location of the site, permits are typically obtained from either county or municipal agencies, such as environmental health/fire departments, water districts, planning departments, and/or building departments. If work is being completed in public rights-of-way(sidewalks areas, roads, etc.), an encroachment permit is often required. If assessment is needed at an off-site location,or if the subject site is no longer owned by the RP,the RP (or RP's agent)will likely need to obtain an access agreement with the owner(s) of the property where work is to be conducted. As part of the well or boring permit process, many regulatory agencies require the property owner to sign forms indicating that the property owner agrees to have the assessment performed. If he or she refuses to grant reasonable access,the regulatory agency may require the property owner to conduct the required work at his/her own expense. This process can be very time-consuming, and should be factored into the schedule for work completion. Regulatory Oversight An inspector from the lead regulatory agency or local oversight agency which has issued a specific permit has the ', N authority to be present during site work, unless prior approval to proceed without an inspector onsite has been obtained. Each agency may have its own specific notification requirements, including notification, or lack thereof, for routine monitoring or maintenance events.The agency has the regulatory authority to reject analytical or field N- results obtained during field work if the proper inspection arrangements have not been made and there is a �i reasonable suspicion that the data are not valid. It is recommended, and may in fact be required by some regulatory agencies, that the RP and consultant contact the regulatory agency to schedule an inspection a minimum of three to five business days (or other agreed-upon interval among RP, consultant, and regulatory agency—the RP is responsible for confirming this interval) before proposed site work begins. If either the date or the field-work schedule is changed from a previously agreed-upon time, whichever party first becomes aware of the change notifies the other parties in the manner previously agreed upon(email,fax,etc.). California LUFT Manual:September 2012 15-6