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LFR Levine-Fricke <br /> Statement of Reasons For <br /> Tracy Tire Site <br /> Remedial Action Plan <br /> Pursuant to California Health and Safety Code(HSC), section 25356.1(e), the <br /> California Environmental Protection Agency(Cal/EPA), Department of Toxic <br /> Substances Control(DTSC)has prepared this Statement of Reasons as part of the <br /> attached Remedial Action Plan(RAP) for Pyrolytic Oil-and Metals-Affected Soil at the <br /> Tracy Tire Fire Site, 29425 South MacArthur Drive, Tracy, San Joaquin County, <br /> California. <br /> The RAP presents a summary of the remedial alternatives evaluated to address the <br /> interim removal action of contaminants detected in soil and tire fire ash. The primary <br /> contaminants detected in shallow soil are metals. The RAP provides a discussion of the <br /> feasible remedial alternatives that were evaluated in the final feasibility study and <br /> recommends a remedial alternative that will meet the objectives of protecting public <br /> health and the environment. The RAP proposes Alternative 3, Excavation of Pyrolytic <br /> Oil-and Metals-Affected Soil for Off-Site Disposal, to remediate the shallow soil, tire <br /> fire ash, and visible pyrolytic oil. The proposed remedial action consists of excavation <br /> of ash, burned material, and pyrolytic oil-and metals-affected soil for off-site disposal. <br /> This RAP has been prepared to address metals in shallow soil, tire fire ash, and any <br /> remaining shallow pyrolytic oil. DTSC believes that the attached RAP complies with <br /> the law as specified in HSC, section 25356.1. Health and Safety Code section <br /> 25356.1(e)requires that RAPs "shall include a statement of reasons setting forth the <br /> basis for the removal and remedial actions selected. The statement of reasons shall also <br /> include an evaluation of the consistency of the removal and remedial actions proposed <br /> by the plan with the federal regulations and factors specified in subdivision(d)..." <br /> Subdivision(d)lists six factors against which the remedial alternatives in the RAP are <br /> evaluated. The proposed remedial action is consistent with the National Oil& <br /> Hazardous Substances Pollution Contingency Plan(the National Contingency Plan <br /> [NCP])and the federal Superfund regulations. The RAP addresses these six factors in <br /> detail and a brief summary follows. The statement of reasons also includes the <br /> preliminary Non-binding Allocation of Responsibility (NBAR)prepared by DTSC as <br /> required by HSC section 25356.l(e). <br /> Health and Safety Risks-HSC Section 25356.l(d)(1) <br /> This RAP has been prepared to address metals in shallow soil, tire fire ash, and any <br /> remaining shallow pyrolytic oil. A Baseline Health Risk Assessment(BHRA)has not <br /> been prepared for the Tracy Tire Fire Site prior to the proposed interim removal <br /> action. The interim removal action is being undertaken to remove visual contamination <br /> due to the tire fire so that a planned Remedial Investigation(RI)may proceed to <br /> characterize the Site and determine if any deep contamination of the soil or <br /> groundwater exists. During the RI a BHRA will be performed to assess the health <br /> risks and set Site cleanup levels for contaminants of concern(COCs). <br /> Final_RAP_Tracy_9.18.03(fina1).doc:LFR Page B-1 <br />