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STATE OF CALIFO,'�NIA - Environmental Prote. , Agency PETE WILSON, Governor <br /> CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD <br /> CENTRAL VALLEY REGION <br /> 3443 Routier Road,Suite A J' E! <br /> Sacramento, CA 95827-3098 <br /> PHONE: (916) 255-3000 �� <br /> FAX: (916) 255-3015 <br /> J AN J 9 1955 6 January 1995 <br /> Mr. Randy Smith <br /> Southern Pacific Transportation Company ENVIRONMENTAL HEALTH <br /> One Market Plaza PERMIT/SERVICES <br /> San Francisco, CA 94105 <br /> WORK PLAN FOR SOUTHERN PACIFIC TRANSPORTATION COMPANY'S OLD TRACY <br /> YARD, SAN JOAQUIN COUNTY <br /> I have reviewed the 18 November 1994 Site Remediation keport/Work Plan and the 28 December <br /> 1994 Additional Analysis Results submitted by Industrial Compliance for Southern Pacific's (SP) old <br /> rail yard in Tracy. A significant amount of soil sampling has better defined the extent of lead <br /> contamination in the shallow soils, and we now concur that other metals do not pose a threat to <br /> ground water. However, soils do contain total lead concentrations exceeding 1,000 mg/kg (hazardous <br /> waste threshold limit), and soluble lead concentrations exceeding 0.05 mg/1 (tentative designated <br /> level). SP has proposed to excavate those soils with total lead concentrations exceeding 500 mg/kg. <br /> In reference to Figures 6, 7 and 8 of the 28 December 1994 submittal, there are areas on the latter <br /> two figures (excavation from 1.0 to 2.5 feet below the ground surface [bgs]) which are not on the <br /> first figure (excavation from 0.0 to 1.0 feet bgs). I am assuming that those areas were meant to be <br /> included on the first figure since it would be physically impossible to not excavate the more shallow <br /> soils in the process of removing the deeper soils. The high soluble lead concentrations in the soils at <br /> SLB-3 are a concern, so that area needs to be excavated to at least 1.5 feet bgs. Similarly, high <br /> soluble lead concentrations found down to three feet bgs at SLB-7 and SLB-10 will require that soil <br /> in those areas also be excavated. <br /> Because lead is generally very immobile and the Board is primarily concerned with protecting the <br /> ground water, all confirmation samples should be analyzed by the waste extraction test in addition to <br /> total lead analyses. <br /> �'he work pian is hereby approved as modified by the above comments. All excavated soil shall be <br /> kept on, and covered by, an impermeable material. A report of the results of the confirmation <br /> sampling and further recommendations regarding any additional excavation and disposal or <br /> remediation of the stockpiled soils shall be submitted by 24 March 1995. The report should also <br /> address the Department of Toxic Substances Control's concern of human health risk of exposure to <br /> lead remaining in the soil. <br /> If you have any questions, you may call me at (916) 255-3077. <br /> JOEL M. WEISS <br /> Engineering Geologist <br /> JMW:jmw/lsb <br /> cc: Ms. Fran Anderson, Department of Toxic Substances Control, Sacramento <br /> Ms. Diane Hinson, San Joaquin County Department of Public Health Services, Stockton <br /> Ms. Tanya Musselwhite, Industrial Compliance, Sacramento <br />