ARCHIVED REPORTS_ROY'S AUTO - HISTORICAL (2)

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FROM Ground. Zero Hna.l ysi s PHONE NO. : 209 952 9892 May. 39 1997 10:59R-1 P2 MEMORANDUM DATE: 05/9/97 TO: DOUG WILSON FROM: GREG STAHL SUBJECT: ROY'S TOWING, 3570 E. MINER, STOCKTON Doug. : Here are my general thoughts as to how we would like to proceed to fully characterize the lead problem at Roy's and arrive at the best remedial solution: I) Collect additional soil samples from approximately 7 locations within and surrounding the known area of impact. Samples to be collected at depths of 1 foot(for further lateral definition) and at depths of 2, 3 & 4 feet (for vertical definition). All samples from 1 foot to be analyzed for STLC lead. Locations that show a problem at 1 foot would have the 2, 3 & 4 foot samples run as well. pH of all analyzed soil samples to be determined as well. 11) Analyze the hottest STLC samples for TCLP lead and STLC lead using deionized water. The purpose of this is to get a better handle on the actual solubility of the lead under environmental conditions. III) Concurrent with the above, a literature search will be conducted (this is already underway) to determine various methods of treatment and stabilization applicable to the situation and which have been proven effective. IV) Based on the results of the above conduct bench-scale testing to evaluate the feasibility and effectiveness of potential treatment/stabilization techniques. V) Select a remedial alternative that bests meets the criteria set forth in the Federal (NCP) and state (H&S Code) environmental regulations. DTSC informs me that the legal and regulatory framework is very well established for alternatives other than disposal at a Class 1 facility. Options range from simply paving, through insitu stabilization or treatment to Class II designated waste standards, or even believe it or not direct disposal at a Class III facility (DTSC has disposed of thousands of yards of lead contaminated soil up to 500 rng/f STLC lead at a Class III when it turned out to be essentially insoluble using DI water extraction). The expense of direct disposal at a Class I facility is so outrageously expensive this should only be considered as a last resort. For instance, Chem Waste - Kctticrnan Sills wants S 125/ton ($170/yard) if TC1-P is less than 5 ppm and 5300+/yard if TCLP is greater than 5. US Ecology in Beatty, NV wants $235/yard. These costs don't include trucking. It is easy to see that direct disposal of even 100 yards of material would involve a very substantial. expenditure