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STATE OF CALIFORNIA—HEALTH AND WELFARE AGENCY GEORGE DEUKMEJIAN, Go. r <br /> DEPARTMENT OF HEALTH SERVICES <br /> TOXIC SUBSTANCES CONTROL PROGRAM <br /> REGION 1 <br /> 10151 CROYDON WAY <br /> SACRAMENTO,CA 95827-2106 April 16, 1990 <br /> (916)855.7700 <br /> VA <br /> APR 1 8 1"R) <br /> Mr. Joe R. Fredrickson ENVIRONMENTAL HEALTH <br /> President PERMIT!SERVICES <br /> y� -1�3 <br /> Eldorado Chemical Co. , Inc. <br /> P.O. Drawer 34837 <br /> San Antonio, Texas 78265-4837 <br /> Dear Mr. Fredrickson: /2?69 nh*r9P2,, SAW <br /> CLOSURE OF INGROUND WASTE STORAGE TANK, ELDORADO CHEMMICAL CO. , <br /> STOCKTON FACILITY, SAN JOAQUIN CO, EPA ID #CAD089681068 <br /> This letter is in response to the letter dated February 22 , 1990, <br /> from Mr. Wayne Smith, consulting engineer for Eldorado Chemical <br /> Co. (ECC) . That letter presented some of the analytical results <br /> for samples collected during removal of the hazardous waste <br /> storage tank. The letter also requested approval to use some of <br /> the excavated soil as backfill. <br /> The Department of Health Services (DHS) is not prepared to make a <br /> determination on the suitability of using this soil as backfill <br /> because ECC has failed to comply with the requirements of the <br /> Closure Plan (CP) approval letter from DHS. This letter, dated <br /> August 8, 1989 , required ECC to establish the extent of <br /> decontamination necessary to satisfy the closure performance <br /> standard of Code of Federal Regulations, Title 40, <br /> Section 265. 111. ECC must clean the contaminated areas to <br /> background levels or establish alternate clean up levels <br /> supported by a health based risk assessment. When acceptable <br /> cleanup levels are established, the contamination levels in the <br /> excavated soil can be compared to the established levels to <br /> determine suitability for backfilling. <br /> ECC has also failed to comply with Item 4 in the CP approval <br /> letter dated August 8 , 1989 - This item required ECC to submit a <br /> plan for additional sampling and remediation if extensive soil <br /> contamination indicated that groundwater contamination was <br /> suspected. The sample collected from underneath the hazardous <br /> waste storage tank contained high concentrations of methylene <br />