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CTATF OF r'AI IFORNIA - F 1 P doh ARgpGy PFTF WII CON Mvwrn <br /> CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD <br /> CENTRAL VALLEY REGION dlll( GI I jj( HEALTH <br /> 3443 Routier Road, Suite A SLERNIGF o. <br /> Sacramento, CA 95827-3098 <br /> PHONE: (916) 255-3000 <br /> FAX: (916) 255-3015 94 AUG —9 Ptd 2' 01 <br /> 2 August 1994 <br /> Mr. Jon Weiss <br /> Libbey-Owens-Ford <br /> P. O. Box 128 <br /> Lathrop, CA 95330 <br /> INTERIM REPORT ON SOIL LEACHING POTENTIAL, LIBBEY-OWENS-FORD <br /> COMPANY, SAN JOAQUIN COUNTY <br /> I have reviewed your 17 June 1994 letter and Condor's Interim Report on its investigation of the <br /> leaching potential of soil contaminated with hydraulic oil and bunker fuel at Libbey-Owens-Ford's <br /> (LOF) Lathrop facility. My comments are presented below. <br /> 1. Your letter stated that the options being considered to treat the contaminated soils at the site <br /> are: 1) onsite bioremediation followed by spreading the treated soils on LOF property; 2) onsite <br /> thermal treatment followed by spreading the treated soils on LOF property; and 3) direct <br /> disposal into an approved landfill. While Option 3 is the least desirable option because of <br /> limited landfill capacity at nearby landfills and throughout the state, the rationale for selecting <br /> Option 1 over Option 2 was not provided. A cost comparison between Options 1 and 2 should <br /> be performed to determine which option is more cost-effective. <br /> 2. Your letter states that a cleanup level significantly lower than the proposed 120 mg/kg TPH will <br /> eliminate onsite bioremediation as an option to treat the contaminated soils but you did not <br /> provide substantiation for your statement. <br /> 3. The report shows that soils contaminated with bunker fuel or hydraulic oil with concentrations <br /> of approximately 100 milligrams per kilogram (mg/kg) total petroleum hydrocarbons did not <br /> have leachable concentrations. Based on this result, LOF proposes to bioremediate the <br /> contaminated soils to 120 mg/kg or a higher concentration which does not show leaching <br /> potential. I concur with the methodology used, the results of the test, and LOF's assertion that <br /> contaminated soils treated to approximately 100 mg/kg will not pose a threat to water quality. <br /> However, the cleanup level should be maintained at 100 mg/kg to be consistent with the San <br /> Joaquin County Public Health Services. <br />