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STATE OF CALIFORNIA - Environmental Protection Agency PETE WILSON, Governor <br /> CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARb`: AI T1 <br /> CENTRAL VALLEY REGION * � <br /> 3443 Routier Road, Suite A - " •�'ss � <br /> Sacramento, CA 95827-3098 <br /> PHONE: (916) 255-3000 ' ' OCT <br /> -7 F!1 1: 26 `°•n,T .'"• <br /> FAX: (916) 255-3015 <br /> 3 October 1994 <br /> Mr. Paul Verma <br /> City of Tracy <br /> Department of Public Works <br /> 520 West Tracy Boulevard <br /> Tracy CA 95376 <br /> SAMPLING AND ANALYSIS OF SOILS STORED AT TRACY AIRPORT, SAN JOAQUIN <br /> COUNTY (CASE NO. 3573) <br /> This letter responds to your letter and sampling and analysis plan dated 7 September 1994 (received <br /> 13 September) and follows up the telephone conference between you and Regional Board staff <br /> members Bill Marshall and Gail Wiggett on 20 September 1994. <br /> During the telephone conversation, you indicated that you needed clarification on what we required <br /> in a sampling plan. You also stated your willingness to comply with our needs and with your Waste <br /> Discharge Requirements (WDRs) Order No. 94-216. <br /> We have reviewed your 7 September proposal and earlier submittals dated 23 August and 31 August <br /> and have considered your concerns as expressed in the 20 September conversation. You have stated <br /> that you wish to be able to dispose of the soils stored at the airport land treatment facility in an <br /> unrestricted manner. To do this, it is necessary, as you know, for the soils to be classified as <br /> "inert". For an inert classification, we require that you demonstrate, using appropriate sampling <br /> and analysis, that the soils will pose no threat to water quality or the environment when disposed of <br /> without restrictions. We must know that the levels of petroleum hydrocarbons that are present in <br /> the soils now, after three years of storage in piles. Based on this, we have the following comments: <br /> 1. Criteria for "Inert" classification• <br /> As we explained in our 2 September 1994 letter to you, Waste Discharge Requirements <br /> Order No. 94-216 specifies the criteria that the soils must meet in order to'be considered <br /> "inert". The criteria are: Gasoline, diesel, and benzene, toluene, xylenes, and ethylbenzene <br /> (BTXE) must not be detectable in representative samples; low concentrations of Total Oil and <br /> Grease (TOG) may be present if the soils are to be placed in City construction projects with <br /> prior approval from Board staff. Board staff will not approve an inert classification for the <br /> soils without analyses showing that heavy hydrocarbon levels meet water quality goals. <br /> Analytical methods are to conform with the requirements of Monitoring and Reporting <br /> Program (MRP) No. 94-216. MRP No. 94-216 specifies that where heavy, straight-chain <br /> hydrocarbon compounds are suspected, an analysis must be performed. The analytical <br /> methods specified in MRP 94-216 are: <br />