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—A Working to Restore Nature cl lns q Fu i. % , 42501 Albrae Street Fremont, California 94538 Phone: (510) 651-1906 FAX: (510) 651-8647 January 14, 1994 Pamela S. Violett R.E.H.S. Public Health Services San Joaquin County 445 N. San Joaquin St. Stockton, Ca. 95201-2009 Re: Newark/Sierra Paperboard sump closure Project Number 780013.01 Ms. Violett, Pursuant to the above referenced project, Resna Industries Inc. would like to request a variance for closure in place of the two tanks and sump located at Newark/Sierra Co. The variance is to do closure without further excavation of contaminated soils for the following reasons: I. The concentration levels of the #4 Fuel oil are between 280 ppm and 600 ppm in the soil samples collected from beneath the tanks and sump. Typically, due to the low solubility of #4 Fuel oil and the concentrations being below 1000 ppm, the Regional Water Quality Board allows these soils to be left in place. 23he sump has a high pressure fire line approximately 8" below the concrete floor. This line was installed in the 1920's and the construction of the line is such that if further excavation should occur the integrity of the line would be compromised causing a loss of the fire suppression system. This would place a severe financial burden placed on Newark/Sierra to replace the entire system as well as having to shut down the plant until a new system is installed. 3. The tank vaults were built as such that the far west end of the vaults are under the above ground condensate tank and the cradles which support the unit. The removal of the floors and the excavation of the soils below the floors will cause a stability problem. Normally shoring the area would be adequate, however due to the fire suppression line, Resna is unable to shore this area to assure integrity of the footings of the building and the cradles holding the tank. 4.There is a 40,000 gallon in -ground tank built decades ago. The outward pressure from the water against the sides of the tank could compromise the integrity of the tank if the floors of the vaults are removed allowing the vault alone to hold the soils and the walls of the 40,000 gallon tank in place.