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Ms. Mea <br /> ys .,. Page 2 <br /> �1. <br /> December 31, 1991 <br /> to obtain a clear.water sample from the bottom°of a tank excavation, it_is <br /> highly likely that the sample contained suspended'sediment and was not- <br /> completely clear. Furthermore, it:is- u_ nknown whether.-- sample was <br /> filtered to remove sediment particles. It is possible that the 2.6 ppm total lead <br /> concentration from this sample resulted from sediment 'within it. <br /> ERM-West subsequently analyzed ground water sainples from monitoring <br /> wells at 1515 West Weber for organic lead; the results indicate that no organic <br /> lead was.detected. Organic.lead, if present,.could conceivably.be attributed-to <br /> a release at the site of leaded gasoline. `.`The absence :of organic lead indicates <br /> that there was no release of lead attributableto�'site-related-activities. <br /> However, to address your concern as'-&pediently as possible, ERM-West will <br /> analyze December .1991 ground_water samples for total lead{:organic and <br /> inorganic) concentrations The data will be-used to assess whether the 2.6 <br /> ppm concentration previously obtained by Kleinfelder was erroneous. <br /> (5) If on-site aeration of soils is conducted at the site, -controlled aeration <br /> techniques .will-be utilized. . This alternative requires that an air pollution <br /> permit be obtained from"the San Joaquin Valley Regional Air Pollution <br /> District. <br /> The X-19 alternative being considered is an innovative, cost effective, on-site <br /> composting alternative utilizing-a-product marketed by .X-19- Biological <br /> Products in San Jose, California.. This alternative involves on-site :treatment, <br /> thereby eliminating the need .to transport the- soil to an off-site-disposal- <br /> facility. <br /> X-19 is a microbiological humic polymer; which -when--mixed with the soil <br /> and placed in a covered pile on-`site, degrades the hydrocarbons to- any. <br /> specified .level (including non-detect) in approximately 90 days. X-19 can <br /> degrade a wide variety of carbon based.. compounds, including numerous <br /> petroleum hydrocarbons, hydrocarbon- insecticides, chlorinated aromatic <br /> compounds, and a wide variety of volatile organic-compounds (VOCs). The <br /> X-19 (applied in a semi-dry state) and-ysoil- are mixed with two front end <br /> loaders in a ratio of three volumes of-.s-oil to---one volume of X-19, and the <br /> mixture is placed in a 4-foot high pile-on a_visqueen blanket (an asphalt pad i <br /> can also be used). The pile is moistened and covered with visqueen to <br /> maintain 'soil m(i:sti•e-.-- --Several sanipl°es-"are --i;ollected -from-the-pile- <br /> throughout the 90-day period to monitor.'the soil moisture, ::temperature,..and <br /> degradation rate... No mixing is.required once the pile is covered; however, an <br /> additional application of water to the surface of the pile may be required to <br /> maintain optimum soil moisture.- X-19 .is moisture adsorbent and thereby <br /> prevents' any leaching of chemical, constituents from the soil pile. The <br /> treated soil has-an .organic matter content of approximately 25% and can be <br /> sold as top:.soihif the_soil does not contain an excessive number of rocks. <br /> 'Feeding -tests have shown X-19`to. be -non-toxic to plants and 'animals. <br /> Permits for the use of X=19 in the environment have been issued by the <br /> California Department of Food and Agriculture.and the U.S. Department of <br /> Agriculture Animal and Plant Health. Inspection -Service. <br />