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LFR Levine-Fricke <br /> Analytical results for metals will be compared to TTLCs, STLCs, and TCLPs <br /> according to the following guidelines: <br /> • Analysis results in excess of TTLC for any CAM-17 metal indicates a Class I non- <br /> RCRA hazardous waste. Analytical results that are less than the TTLC but in <br /> excess of 10 times the STLC for any CAM-17 metal requires that the sample also <br /> be analyzed using the Waste Extraction Test(WET). Based on the preliminary <br /> RI/FS, Class I RCRA waste is not anticipated, so the TCLP will be run as needed <br /> only. If the sample exceeds the STLC following the WET, Class I non-RCRA <br /> disposal is indicated. If, following the WET, the sample does not exceed the STLC <br /> for any of the CAM-17 metals, then Class I non-RCRA disposal is not required and <br /> the soil will be evaluated for classification as a designated Class II waste or non- <br /> hazardous Class III soil as described in the next paragraph. <br /> • Soils containing concentrations of metals that are less than Class I non-RCRA <br /> action levels or that contain VOCs or SVOCs will be evaluated for disposal in a <br /> Class II or III landfill facility, as appropriate. Class II and III landfills have permits <br /> with different waste acceptance criteria; therefore, various Class II and III landfills <br /> will be contacted with analytical results for potential disposal at a permitted landfill. <br /> There is no California standard for defining wastes as Class II or Class III. <br /> A Class I landfill is permitted to accept waste that exceeds state and/or federal leaching <br /> criteria. Soil may be classified as a federal Class I RCRA hazardous waste if the <br /> concentration exceeds the federal toxicity characteristic limits defined in Title 40 CFR <br /> §261. The federal standards are based on soluble concentrations from the Toxicity <br /> Characteristic Leaching Procedure(TCLP). If the soluble concentration of a sample <br /> exceeds the TCLP, then the waste is classified as a federal hazardous waste(i.e., <br /> RCRA waste). A RCRA waste requires treatment before it can be disposed of in a <br /> Class I landfill. <br /> Soil may be classified as a Class I California hazardous waste (Class I non-RCRA <br /> hazardous waste)if it exceeds the toxicity levels listed in Title 22 CCR, Division 4.5, <br /> Chapter 11, Article 5, §66261.101. The California toxicity levels are divided into two <br /> separate concentration limits. The waste concentrations are evaluated using both the <br /> Total Threshold Limit Concentration(TTLC)and Soluble Total Limit Concentration <br /> (STLC). If the total concentrations exceed the TTLC or the soluble concentrations <br /> exceed the STLC, then the waste is classified has a California hazardous waste. State <br /> regulations allow the use of a screening value for total concentrations before the STLC <br /> test is performed. For example, the screening level of 10 times the STLC concentration <br /> for TTLC concentration can be used. <br /> A Class II landfill is permitted to accept waste that does not exceed Class I criteria, but <br /> is not considered sufficiently clean to be sent to a Class III Sanitary Landfill (i.e., may <br /> contain petroleum hydrocarbons)as determined by the acceptance criteria of the <br /> individual landfills. <br /> Page 38 Final_RAP_Tracy_9.18.03(final).doc <br />