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STATE,OF CALIFORNIA—HEALTH AND WELFARE AGENO • GEORGE DEUKMEAAN. Govemor <br /> DEPARTMENT OF HEALTH SERVICES ; <br /> 714/744 P STREETt <br /> SACRAMENTO, CA 95814 ~-` <br /> (916) 322-3670 <br /> July 29, 1988.( M <br /> Mr. William S. Rickman <br /> Ogden Environmental Services, Inc. VVV v <br /> P. 0. Bax 85178 AUG 1988 <br /> San Diego CA 92138 <br /> ENVIROMENTAL HEALTH <br /> Dear Mr. Rickman: PERMIT/SERVICES <br /> VARIANCE FROM DEPARTMENT OF HEALTH SERVICES PERMIT REQUIREMENTS - FOR <br /> DEMONSTRATION OF CIRCULATING BED COMBUSTOR TECHNOLOGY AT THE FORMER TILLIE LEWIS <br /> FOODS CANNERY SITE, STOCKTON, CALIFORNIA <br /> The Toxic Substances Control Division, Alternative Technology Section (ATS) , has <br /> received your dated May 19, 1988 request for a variance from the Hazardous Waste <br /> Facility permit requirements of Chapter 30, Division 4, Title 22, California <br /> Code of Regulations (CCR) . Your request for a variance is to demonstrate the use <br /> of a transportable circulating bed combustor (CBC) to clean up : 6 fuel oil <br /> contaminated soil from a Leaking Underground Fuel Tank (LUFT) site. In support <br /> of the variance application, you have submitted the following documents: 1) Site <br /> Assessment Report dated May 1988; 2) Final Remedial Plan dated May 1988; 3) CBC <br /> System Field Performance Assessment Plan dated July 1988; 4) Thermal Treatment <br /> System Operation Plan dated June 1988; 5) Health and Safety Plan dated July <br /> 1988; 6) Emergency Response Plan dated June 1988; and 7) Sampling and Analysis <br /> Protocol dated June 1988. <br /> The variance is based primarily on the following supportive facts: <br /> 1. The CBC technology site remediation demonstration will be conducted at the <br /> Former Tillie Lewis Foods Cannery (site) , 1405 South Fresno Avenue, <br /> Stockton, California. <br /> 2. The CBC technology will be used to remediate approximately 7,000 cubic <br /> yards of soils contaminated with # 6 fuel oil. The soil contaminant <br /> concentrations vary from >5 to 30,000 ppm with an average concentration of <br /> approximately 1,800 ppm. The site remediation is scheduled to start in <br /> September 1988 and is expected to take from six to nine months to complete. <br /> 3. Steady-state data will be collected on a full-scale operation at a LUFT <br /> site to evaluate performance of the CBC technology. In addition to <br /> continuous monitoring for total petroleum hydrocarbons in the stack <br /> emissions, a detailed demonstration test will be conducted over a 24 hour <br /> period after a shake down period of two months to four months of operation. <br /> The ATS has reviewed your submittals and has made the following detexnlinations: <br /> Based upon the authority granted to the Department of Health Services (DHS) in <br /> Section 25143 of the Health and Safety Code (HSC) , and in Section 66310(a) (1) of <br /> the CCR, we find that the # 6 fuel oil contaminated soil to be insignificant as <br />