Laserfiche WebLink
t GEORGE DEUKMEJIAN,Governor <br /> STATE OF CAIIFORK'A <br /> 11 <br /> CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD— <br /> CENTRAL VALLEY REGION <br /> 3443 ROUTIER ROAD <br /> SACRAMENTO,CA 95827-3098 <br /> AUG u � 1989 <br /> '17"'!VENTAL V- <br /> 22 August 1989 <br /> Mr. Harry Mossberger <br /> Kearney-KPF <br /> P.O. Box 8485 <br /> Stockton, CA 95208 <br /> REVIEW OF REVISED CLOSURE PLAN, KEARNEY-KPF, SAN JOAQUIN COUNTY <br /> I have reviewed the 20 July 1989 Revised Closure Plan submitted by Hargis and <br /> Associates. Most of this document remains unchanged from the 30 May 1989 Closure <br /> Plan. My review of the Revised Plan has concentrated on the sections which have <br /> had major changes, such as the soil assessment sampling plan and Appendix F. <br /> My concerns with the proposals for the soil assessment are listed below; the <br /> Revised Plan is not acceptable unless the following comments are satisfactorily <br /> addressed. <br /> 1. You propose to determine the soluble metal concentration of background <br /> soils by dividing the known total metal concentration by 100. You also <br /> appear to propose to analyze five surface soil samples at the site for <br /> soluble metal concentrations and total metal concentrations, and to use <br /> this soluble-to-total relationship as characteristic of the background <br /> soils. These proposals are unacceptable because the former is based on <br /> a divisor and not on data, and the latter is based on too meager of a <br /> sample population to be representative of all soil conditions at the site. <br /> 2. Moreover, you do not include analysis of cadmium, molybdenum, and cyanide <br /> in your proposal - These chemicals must also be analyzed in those Soil <br /> samples collected for the purpose of establishing background soluble metal <br /> concentrations because their presence in the area has been established and <br /> they must be considered in the site closure. <br /> 3. Your proposal to use deionized water in the Waste Extraction Test on the <br /> soils which are acidic is not acceptable. Section 66700 of Title 22 of <br /> the California Code of Regulations requires the use of citric acid. <br /> Therefore, soil samples from the drainage area south of galvanizing <br /> building, from Pond 1 and from other areas with acidic conditions may not <br /> be analyzed with deionized water. <br /> 4. You state that a 40 foot soil boring depth is in accordance with the <br /> Regional Board's comments. That depth was chosen in previous <br /> investigations because the water table was approximately 40 feet below <br />