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FROM Ground Zero Analysis PHONE NO. : 209 952 9892 r1ay. O9 99? 10:59pfl P2 <br /> MEMORANDUM <br /> DATE: 05/9/97 <br /> TO: DOUG WILSON n <br /> FROM: GREG STAI3L, <br /> SUBJECT: ROY'S TONVING, 3570 E. MINER, STOCKTON <br /> Doug: . Here are my general thoughts as to how we would like to proceed to fully characterize <br /> the lead problem at Roy's and arrive at the best remedial solution: <br /> 1) Collect additional soil samples from approximately 7 locations within and surrounding <br /> the known area of impact. Samples to be collected at depths of 1 foot(for further lateral <br /> definition) and at depths of 2, 3 & 4 feet (for vertical definition). <br /> All samples from 1 foot to be analyzed for STLC lead. Locations that show a problem <br /> at 1 foot would have the 2, 3 &4 foot samples run as well. <br /> pH of all analyzed soil samples to be determined as well. <br /> II) Analyze the hottest STLC samples for TCLP lead and STLC lead using deionized water. <br /> The purpose of this is to get a better handle on the actual solubility of the lead under <br /> environmental conditions. <br /> III) Concurrent with the above, a literature search will be conducted (this is already <br /> underway) to determine various methods of treatment and stabilization applicable to the <br /> situation and which have been proven effective. <br /> IV) Based on the results of the above conduct bench-scale testing to evaluate the feasibility <br /> and effectiveness of potential treatment/stabilization techniques. <br /> V) Select a remedial alternative that bests meets the criteria set forth in the Federal (NCP) <br /> and state (H&S Code) environmental regulations. <br /> DTSC informs me that the legal and regulatory framework is very well established for <br /> alternatives other than disposal at a Class I facility. Options range from simply paving, through <br /> insitu stabilization or treatment to Class II designated waste standards, or even believe it or not <br /> direct disposal at a Class III facility (DTSC has disposed of thousands of yards of lead <br /> contaminated soil up to 500 mg/f STLC lead at a Class III when it turned out to be essentially <br /> insoluble using DI water extraction). <br /> The expense of direct disposal at a Class I facility is so outrageously expensive this should only <br /> be considered as a last resort. For instance, Chcm Waste - Kettle:nan Hills wants $125/ton <br /> ($170/yard)if TCLP is less than 5 ppm and S300+/yard if TCLP is greater than 5. US Ecology <br /> in Beatty, W wants$235/yard. These costs don't include tricking. It is easy to see that dimet <br /> disposal of even 100 yards of material wou'd involve a very substantial expenditure <br />