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r <br /> WATERWORK <br /> . GEOCHEMICAL•GEOTECHNICAL• ENVIRONMENTAL <br /> A 'W2 -JTTI� <br /> October 8, 1990 <br /> OCT 9 19"D <br /> ENVIRONMENTAL HEALTH <br /> Ms. Margaret Legorxo PERMIT/SERVICES <br /> San Joaquin County <br /> Public Health Services <br /> Environmental Health Division <br /> P.O. Box 2009 <br /> Stockton, CA 95201 <br /> Re: BJJ Company/Heinz Facility - 757 East 11th Street, <br /> Tracy, Site Code 1926 <br /> As we discussed previously, BJJ Company has excavated <br /> approximately 850 cubic yards of somal from a former diesel fuel <br /> tank pit at the subject site. Soil excavation was proposed in <br /> the February 26, 1990 Problem Assessment Report. The soil has <br /> non-detectable to moderate concentrations of diesel fuel as <br /> . determined from 23 representative composite somal samples <br /> collected by a WaterWork Corporation staff geologist pursuant to <br /> WaterWork ' s Quality Assurance/Quality Control Plan ( see PAR <br /> Appendix III ) . <br /> Laboratory results are summarized in Table 1 . Laboratory data <br /> sheets are included in Attachment 1 . Benzene was present in only <br /> one sample at the detection limit of 5 ppb. Insignificant levels <br /> of toluene and ethylbenzene were detected in only two samples and <br /> xylenes in three samples. The average concentration of total <br /> petroleum hydrocarbons as diesel for the entire volume of soil is <br /> 186 ppm. This value was determined conservatively by using the <br /> detection limit where non-detectable levels were found. <br /> A value of 1000 ppm TPH has generally been accepted by the <br /> Regional Water Quality Control Boards and Department of Health <br /> Services as a discretionary "rule-of-thumb" value for defining a <br /> hazardous waste. Considering that diesel oil is present in <br /> concentrations equal to or exceeding this value from everyday <br /> practices such as weed control, dust prevention, asphalt paving, <br /> and mosquito abatement, use of the 1000 ppm cutoff previously has <br /> been acceptable. It is likely that San Joaquin County itself is <br /> performing these practices regularly with no consideration to <br /> whether a "hazardous waste" as being created. <br /> In spite of current uses and statewide policies regarding diesel <br /> . oil, we understand that San Joaquin County also requires <br /> characterization of soils pursuant to Title 22, Article 11 before <br /> 1710 MAIN STREET • ESCALON CA 95320 • (209) 838-3507 <br /> FRESNO CA(209) 222-3495 9 RENO NV(702) 788-6830 <br />