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I* , ', • <br /> Mr. Verma 2 2 Sept. 1994 <br /> Soils Disposal Criteria <br /> waste chemical compounds or taste- and odor- causing constituents may not be discharged at levels <br /> that may cause impairment of beneficial uses of waters. Based on this authority, Board staff may <br /> determine water quality goals on a case-specific basis even when there is no published numerical <br /> goal. <br /> In the case of Bunker oil and oil and grease compounds (TOG), which are known or suspected to be <br /> present in the soils stored at the Tracy Land Treatment Facility, neither the Basin Plan nor Order <br /> No. 94-216 specifies a numerical criterion. Therefore, in order to establish a goal in response to <br /> your request for unrestricted disposal of the soils, staff has applied the taste and odor criterion using <br /> a dilution ratio (threshold odor number) derived from the publication, Water Quality Criteria <br /> (McKee and Wolf, 1963), published by State Water Resources Control Board. Expressed as parts <br /> per billion (ppb) and adjusted for attenuation and leachability, that number is 13 ppb for Bunker <br /> oil. <br /> MRP No. 94-216 specifies analysis by USEPA method 5520 E/F for TOG. This is the same <br /> method that was used by Harding Lawson Associates, in a Phase 1 Site Characterization Report <br /> dated August 2, 1989, for the Schulte Road site of origin of the Bunker-containing soils. This work <br /> was used and referenced in 1991 as a basis for further proposals on your behalf by WaterWork <br /> (letter to Robert Evans, dated 7 May 1991, regarding the Schulte Road extension project. This <br /> method was chosen by staff for specification in the MRP for consistency's sake. It is also the <br /> method preferred in the latest edition of the Tri-Regional Board Staff Recommendations for <br /> underground tank sites, 10 August 1990. The MRP also specifies analytical methods for other <br /> constituents of concern. <br /> In summary, then, the criteria that your soils will have to meet are those listed in Discharge <br /> Specification B.4 of Order No. 94-216, and 13 ppb of TOG as determined by staff under authority <br /> of the Basin Plan and the WDRs. The analytical methods that are appropriate are those specified in <br /> MRP 94-216. <br /> Board staff may not alter the requirements set forth in WDRs or other Board orders. Only the <br /> Board may change a Board order. Therefore, in order to dispose of the soils under an "inert" <br /> classification, you must meet the terms of the existing WDRs and accompanying MRP, or petition to <br /> have them changed. <br /> If you have any questions, please contact Gail Wiggett at (916) 255-3119. <br /> X1'" � It <br /> THOMAS R. PINKOS <br /> Supervising Water Resources Control Engineer <br /> GJW:gw <br /> cc: Ed Padilla, San Joaquin County Public Health Department, Stockton <br /> Danny Mercer, Wright Environmental <br /> Jon Marshack, RWQCB <br />