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STATE OF CALIFORNIA • • GEORGE DEUKMEJIAN. Governor CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD— CENTRAL VALLEY REGION 3443 ROUTIER ROAD. SUITE A 4 SACRAMENTO. CA 95827-3098 19 December 1990 Mr. Paul Verma Department of Public Works City of Tracy 520 West Tracy Boulevard Tracy, CA 95376 SECOND REQUEST FOR REPORT OF WASTE DISCHARGE AND REVIEW OF DRAFT SPECIFICATIONS FOR BIOREMEDIATION PROJECT, TRACY MUNICIPAL AIRPORT, (BECK DEVELOPMENT PROPERTY), TRACY, SAN JOAQUIN COUNTY (CASE# 2946) We have reviewed the draft bioremediation project specifications given to us in the S December 1990 meeting at your office and the 11 December 1990 letter discussing that meeting. Comments and issues regarding the draft specifications which need to be addressed are stated below. Additionally, statements made in the 11 December 1990 letter are not consistent with our understanding of how the major issues were resolved. We stated that the City had three basic options as far as handling the contaminated soils excavated from the Schulte road site. First, the City could take the soil to a permitted disposal facility. Second, the City could leave the soil on Beck Development property adjacent to the excavation site. Thirdly, the City could take the soil to the proposed site of the land treatment facility and incur the risk of having to move the soil again if required. It should be understood that the decision to excavate the soil and exercise one of the above options, as well as obtain the required permits, remains the responsibility of the City. In regards to your statement that we agree that the soil is not hazardous, this statement is not true. We said, based on the data verbally presented to date by the City, the soil is probably not hazardous. We stated that levels of oil and grease above 1000 mg/kg may not be hazardous if the City had conducted Title 22, California Code of Regulations tests to see if the material was hazardous. In your draft specifications, you state that the contaminated soil contains up to 11 , 100 ppm of oil and grease which is four to six times higher than indicated in prior conversations. The City to date has not submitted any actual analytical results from recent samples taken from the excavation site to demonstrate that the soils are not hazardous and need not be managed as a hazardous waste. However, we stated that the City could submit a letter stating that they were self-certifying that the soils were not hazardous along with the data and documentation supporting the certification. We also asked the City to send a copy of the self-certification to the Department of Health Services for review.