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Ms. Donna Heran <br />February 22, 1999 <br />Page two <br />• In addition, the published background data for lead in soils in the western <br />United States has an arithmetic mean of 20 mg/kg with a concentration range <br />from less than 10 to 700 mg/kg (based on " Element Concentrations in soil <br />and other surficial Materials of the Conterminous United States", U.S. <br />Geological Survey Professional Paper 1270, 1984). In light of the above and <br />since there were no free products in the soils, it reasoned that the lead <br />concentrations detected are background levels for the area. In addition, lead <br />concentrations in all samples are several orders of magnitudes below the total <br />threshold limit concentration (TTLC) value of 1,000 mg/kg. The TTLC value, <br />per title 22 of the California Code of Regulations (CCR), is the concentration <br />of a solubilized, extractable and non -extractable bio -accumulative or <br />persistent toxic substances which, if equaled or exceeded in a waste, renders <br />the waste hazardous characteristics. <br />In light of the above and in closing, the Port requests that a written closure <br />letter regarding these sites be provided to us. In addition, the Port is providing <br />copies of these results to your staff (Mss., Lagorio and Oz). The Port would like <br />to appreciate the continued spirit of partnering, cooperation and assistance that <br />has been extended to us by you and your Division staff. If you or members of <br />your staff have any questions regarding this, please contact Mr. Barry Nicholson <br />of my staff or myself at 209-946-0248. <br />Sincerely, <br />Jay R. Ja angiri, M.S., REM, REA <br />Director of Environmental and Regulatory Affairs <br />JRJ/bs <br />Enclosures <br />cc: Alexander Krygsman, Port Director <br />Leroy Hieber, Deputy Port Director <br />Gary Gentry, Director of Facilities Maintenance & Construction <br />Mark Tollini, Director Maritime Affairs <br />Tim Loveland, Facilities Maintenance & Construction Manager <br />Barry Nicholson, Environmental Specialist <br />Margaret Lagorio, REHS <br />Carol Oz, REHS <br />