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STATE OF CALIFORNIA - Environmental Prot�CCon Agency PETE WILSON, Governor <br /> CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD <br /> CENTRAL VALLEY REGION <br /> 3443 Routier Road, Suite A <br /> Sacramento, CA 95827-3098 <br /> PHONE: (916) 255-3000 <br /> FAX: (916) 255-3015 p%sivEg2 Sept 1994 <br /> Mr. Paul Verma <br /> SEP U G 1994 <br /> City of Tracy <br /> EN <br /> Department of Public Works ENVIRONMENTAL <br /> LTH <br /> /SE VICES <br /> 520 West Tracy Boulevard <br /> Tracy, Ca 95376 <br /> TESTING AND UNRESTRICTED RE-USE OF SOILS FROM TRACY AIRPORT LAND <br /> TREATMENT FACILITY, SAN JOAQUIN COUNTY (CASE NO. 3573) <br /> This letter responds to several recent telephone inquiries and facsimile-transmitted draft proposals <br /> submitted on your behalf during the past ten days by Wright Environmental Services. It is our <br /> understanding that the most recent proposal, which was submitted via facsimile on 31 August at <br /> approximately 3:00 p.m., supersedes and renders inoperative the other communications. It is that <br /> proposal to which this letter specifically responds. <br /> We agree that unrestricted re-use of the soils stored at your Tracy airport site is appropriate if the <br /> soils can be shown to be "inert" . Application of the term "inert" requires that the wastes, or soils, <br /> be non-reactive and pose no threat to water quality under the conditions of any potential foreseeable <br /> re-use situation. This concept differs from the concept of a "designated" waste, which applies to a <br /> waste that could pose a threat to water quality under the conditions of the proposed re-use. To re- <br /> use a soil that is "designated", certain conditions must be met; for example, it might be necessary to <br /> encapsulate the soils or to restrict the types of uses. For unrestricted uses, the soils must meet <br /> criteria that show them to be inert under use conditions that provide no additional protection or <br /> isolation. <br /> The criteria your soils must meet to receive an "inert" classification are listed in the Waste <br /> Discharge Requirements Order 94-216, Discharge Specification B.4. Additionally, the specification <br /> states that analytical methods shall be as specified in Monitoring and Reporting Program (MRP) No. <br /> 94-216. The MRP specifies that where heavy, straight-chain hydrocarbons (oil and grease) are <br /> known or suspected to be present, an analysis must be performed. Discharge Specification B.4.b <br /> states that treated soil containing low concentrations of total oil and grease (TOG) may be returned <br /> to the site of origin or used in City construction projects provided prior approval is obtained. For <br /> unrestricted uses, TOG levels must qualify as inert, i.e, the concentrations must meet water quality <br /> goals. Order No. 94-216 does not specify an "inert" concentration level for TOG or Bunker oil. <br /> However, the Order implements the water quality objectives stated in the Regional Board's Water <br /> Quality Control Plan, ("Basin Plan"). <br /> Numerical goals or concentration levels are not uniformly established by USEPA, California <br /> Department of Health Services, or other appropriate authorities for all compounds or constituents. <br /> The Basin Plan uses narrative goals for many constituents, and imposes standards which require that <br />