SITE INFORMATION AND CORRESPONDENCE

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Mr. Verma -2- 20 June 1994 As stated before, we require confirmation of the contamination levels in the soils before their removal and reuse. We require that analyses be performed, or records of prior analyses be submitted, to show that Bunker oil and other TOG levels are below 800 ppm. The analysis used previously for TOG was Standard Method 5520 E/F. Use of that method is acceptable, but we ask that you field-check the soils during removal with a Combustible Gas Indicator or appropriately- equipped Photoionization Detector to ensure that soils removed from the site do not contain significant levels of hydrocarbons and that site personnel are not exposed to fumes. In addition, in order to verify the levels of Total Petroleum Hydrocarbons (gasoline or diesel) (TPH-g, TPH-d), and BTXE, we require current analyses of representative composite samples from within the soil piles, using appropriate analytical methods. We recommend USEPA Methods 8020 or 8240 for BTXE, 5030 (GCFID) for TPH-g, 3550 (GCFID) for TPH-d, or USEPA Method 8260 (cryogenic focusing) for TPH and BTXE. For all analyses, the laboratory should report all peaks, whether identifiable or not, and should explain all departures from the lab's practical quantitation (detection) limit. We will not approve re-use of soils containing detectable levels of BTXE or other volatile or soluble components. We will not approve biotreatment or re-use of soils from other projects without current analyses. We are proceeding with drafting Waste Discharge Requirements (WDRs) for your proposed biological treatment of the remaining soils stored at the facility. Regional Board staff are not authorized to waive WDRs for this project. If you have any questions, please call me at (916) 255-3119. GAIL WIGGETT Associate Engineering Geologist cc: Ed Padilla, San Joaquin County Public Health Services, Stockton David Kwong, San Joaquin Valley Air Pollution Control District, Stockton , I t} di S' � I