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PAGE TWO - MARGARET LAGORIO <br /> UNIT. WITH NO CLEAR DEFINITION, AS IS THE CASE WITH PETROLEUM CONTAMINATED <br /> SOILS, THE REGIONAL BOARDS HAVE HAD TO MAKE THE CLASSIFICATION. <br /> UNLIKE THE FEDERAL REGULATIONS, CALIFORNIA REGULATIONS INDICATE THAT MEDIA <br /> AND DEBRIS CONTAMINATED WITH PETROLEUM FROM A UST IS SUBJECT TO THE TOXICITY <br /> CHARACTERISTIC AS A CRITERIA FOR HAZARDOUS WASTE. THE APPLICATION OF THE TC <br /> STANDARD TO A UST SITE COULD OSTENSIBLY RESULT IN SOIL BEING CLASSED AS A "TOXIC" <br /> HAZARDOUS WASTE WHICH IT WOULD NOT UNDER RCRA. THE GENERAL POSITION OF THE <br /> DSTC RELATIVE TO THE OTHER THREE CHARACTERISTICS IS THAT WASTE SOIL CONTAMINATED <br /> WITH HYDROCARBONS WOULD NOT BE EXPECTED TO EXHIBIT CORROSIVITY OR REACTIVITY. <br /> IGNITABILITY IS CONTROVERSIAL. WITHOUT FREE PHASE GASOLINE PRESENT, FUEL HYDROCARBON <br /> CONTAMINATED SOIL WOULD NOT BE EXPECTED TO EXHIBIT IGNITABILITY CHARACTERISTICS. <br /> REGARDLESS, REGULATORS FREQUENTLY REQUIRE DISPOSAL OF HYDROCARBON CONTAMINATED <br /> SOILS IN CLASS I AND CLASS 'II SITES WITH A COSTLY AND NEEDLESS EXPENDITURE OF <br /> MONEY AND MATERIALS TO ALREADY OVERBURDENED LANDFILLS. <br /> A COMMONLY APPLIED CRITERIA ALSO INVOLVES THE 1,000 PPM TPH THRESHOLD <br /> TO DETERMINE IGNITABILITY CHARACTERISTS OF GASOLINE CONTAMINATED SOIL. THIS IS <br /> NOT A REGULATORY REQUIREMENT. THE TEST FOR INGITABILITY FOR NON LIQUIDS IS <br /> WHETHER THE NON LIQUID ". . . IS CAPABLE UNDER STANDARD TEMPERATURE AND PRESSURE, <br /> OF CAUSING FIRE THROUGH FRICTION, ABSORPTION OF MOISTURE OR SPONTANEOUS CHEMICALS <br /> AND, WHEN IGNITED, BURNS SO VIGOROUSLY AND PERSISTENTLY THAT IT CREATES A HAZARD". <br /> (22 CALIFORNIA CODE OF REGULATIONS SECTION 66261.21 (A)(2) ). THIS STANDARD IS <br /> AMBIGUOUS AND IMPRECISE - AT BEST. <br /> ANOTHER WASTE OF MONEY AND MISUNDERSTOOD FREQUENTLY QUOTED REQUIREMENT IS THE <br /> 96 HOUR FISH BIOASSAY TEST, THE WASTE EVALUATION UNIT OF DTSC HAS BEEN ADVISING <br /> GENERATORS TO PERFORM THIS TEST. IT IS NOT A REGULATION. HOPEFULLY, THE PROMISED <br /> REVISION OF THE LUFT MANUAL SCHEDULED FOR SEPTEMBER, 1993 WILL REFUTE SOME OF <br /> THESE COMMONLY HELD MISCONCEPTIONS. THERE IS ANOTHER MISCONCEPTION REGARDING THE <br /> "GENERIC" TPH CONCENTRATION CLEANUP LEVELS FOR HYDROCARBON CONTAMINATED SOILS <br /> WHICH IS BASED ON THE LUFT MANUAL AND MISINTERPRETATING THE "RECOMMENDTAIONS FOR <br /> PRELIMINARY EVALUATION AND INVESTIGATION OF UNDERGROUND TANK SITES" (TRI-REGIONAL <br /> GUIDELINES). THE LUFT MANUAL (1989) TABLE 2-1 PURPORTS TO SET "CLEANUP" VALUES <br /> FOR BTEX AND TPH WHICH VALUES ARE BASED ON LEACHING POTENTIAL OF THE SITE BEING <br />