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i Kennedy/Jenks/Chifton Mr. Charles Whitworth • Cal -Farm Supply 14 July 1989 € Page 14 1 First-Third Land Ban wastes. They are "soft hammer" wastes which means that the EPA has not developed treatment standards or technologies. Class I disposal facilities are not accepting this waste until the EPA finalizes treatment standards. Therefore, ' excavation and disposal at a Class I hazardous waste facility is dependent on the time EPA finalizes treatment standards. o Another option would be to excavate and store on site the DDT-bearing soils until acceptable treatment technologies are identified by the EPA. Although this may be technically feasible, the Cal-Farm Stockton property may then be considered as a Transfer, Storage, and Disposal (TSD) facility requiring appropriate permits. Therefore, this alternative may not be practical . Additional samples are proposed in the area south of SS-10 and SS-11 outside of the facility's fence (see Figure 7) . Additional samples are also proposed within the shaded area east of the main warehouse building, also shown on Figure 7, to further characterize concentration of DDT in this area. It is also proposed to estimate health-based cleanup levels consistent with future uses of the property. Pesticide Storage Trailers and Contents It was determined during this investigation that the five, five-gallon containers of Ordram 8-E may be accepted by a local pesticide distributor. This material may be given away or possibly sold by the distributor The eight or nine five-gallon containers of Silvisar 550 also are intact and could be utilized if a Silvisar user is identified. A supplier to take the Silvisar 550 has not been identified at this time We recommend that we continue to locate a possible applicator of pesticides who is interested in using the Silvisar 550. The corroded nature of the Alfa-Tox containers prohibits its utilization as a pesticide. The Alfa-Tox should be disposed of at a Class I landfill . In a previous discussion with the Class I facility operators, it was indicated that confirmation analyses would not be necessary if the material was in the original containers. However, due to the corroded nature of the container, sampling and analyses may be required prior to disposal The Silvisar and Ordram should be utilized for their intended purposes unless a distributor cannot be found to accept and use this material . In this case, the pesticides should be disposed of at a Class I landfill The large storage trailers can be recycled as scrap metal if the containers do not contain significant amounts of pesticide residues. Additional wipe samples will be required to determine the level of residues present. If the I i