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STATE OF CALIFORNIA- Environmental Protection Agency PETE WILSON, Governor <br /> CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD . � <br /> CENTRAL VALLEY REGION <br /> 3443 Routier Road, Suite A <br /> Sacramento, CA 95827-3098 <br /> PHONE: (916) 255-3000 <br /> FAX: (916) 255-3015 <br /> 24 June 1994 <br /> Mr. Randy Smith <br /> Southern Pacific Transportation CompanyD One Market Market Plaza b <br /> San Francisco, CA 94105 <br /> SOUTHERN PACIFIC TRANSPORTATION COMPANY, OLD TRACY YARD, SAN <br /> JOAQUIN COUNTY <br /> We have reviewed your 10 May 1994 letter regarding soil remediation activities to occur at the <br /> subject site. Southern Pacific Transportation Company (SPTCo) has set two conditions before it <br /> will begin soil remediation work: State acceptance of the proposed 500 mg/kg soil cleanup level for <br /> lead and Board approval to run the Waste Extraction Test (WET) only for metals whose total values <br /> exceed 10 times the soluble threshold limit concentration (STLC). Both of these conditions are <br /> unacceptable. <br /> As described in the enclosed memorandum from the Department of Toxic Substances Control <br /> (DTSC), SPTCo's proposed cleanup level of 500 mg/kg of lead is not appropriate. The DTSC also <br /> needs additional information to determine if the elevated levels of certain metals pose a human <br /> health threat. <br /> In our 21 April 1994 letter, we stated that SPTCo must include soluble analyses using the WET of <br /> barium, cadmium, copper, mercury and zinc as part of the work plan for further site <br /> characterization. Your 10 May 1994 letter requested the sampling protocol summarized above. As <br /> we have already stated, threshold limits are used to determine if a soil is classified as hazardous <br /> waste and have nothing to do with determining appropriate soil cleanup levels. Therefore, you are <br /> required to use the WET on the soil samples when analyzing for metals. <br /> Regarding the work schedule, there is no need to submit a revised work plan (Task 1) as outlined in <br /> your May 1994 letter. I suggest we schedule a meeting, including the DTSC, to resolve the two <br /> outstanding issues. Once these are resolved, work plan implementation (Task 2) can proceed. <br /> jUN 2 7 1994 <br /> ENVIRONMENTAL <br /> TISERVICESLTH <br />