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As indicated in Table I, the borrow area soil sample TTLC concentrations are well below <br /> the regulatory levels which characterize a material as hazardous. LOF and Condor further <br /> believe that the TTLC concentrations are within the range which can be expected as <br /> background or naturally occurring at the Lathrop site. In addition to the TTLC analysis, the <br /> parameters arsenic, copper and selenium were selected for STLC analysis. These elements <br /> are believed to have been used in agricultural applications and/or the glass manufacturing <br /> process over time at the Lathrop site. The leachability of arsenic, copper and selenium from <br /> the soil samples were evaluated by measuring the STLC. As shown in Table I, the STLC <br /> concentrations of the three parameters are below the primary drinking water standards <br /> (MCL's). Therefore, LOF and Condor believe that the soil in the borrow area is suitable <br /> for backfill material. <br /> LOF believes that to date, it has taken all necessary and appropriate steps in its response <br /> to the fuel oil release at its Lathrop site. Accordingly, LOF requests that the RWQCB <br /> provide its concurrence to backfill the Lathrop site excavation area with the borrow area soil <br /> as described above. LOF continues to look forward to working with RWQCB to ensure that <br /> all reasonable mitigative measures are taken to ensure that any potential threat to human <br /> health or the environment remains fully abated. <br /> Should you have questions or comments regarding this matter, please contact Chuck <br /> Baumgartner, of my staff, at (419) 247-3746 or Kim Reed, Lathrop on-site coordinator, at <br /> (209) 858-6318 or me at (419) 247-3715. I will be contacting you in the very near future to <br /> discuss proceeding with the backfilling activities. <br /> Sincerely, <br /> Yhn <br /> Keil Manager <br /> Environmental Affairs <br /> cc: Ms. Patricia Leary <br /> Water Resource Control Engineer <br /> California Regional Water Quality Control Board <br /> Central Valley Region <br /> 3443 Routier Road, Suite A <br /> Sacramento, California 95827-3098 <br /> Ms. Diane Hinson <br /> San Joaquin County Public Health Services <br /> Environmental Health Division, Unit IV <br /> 445 N. San Joaquin Street <br /> P.O. Box 2009 <br /> Stockton, California 95201 <br />