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• The above described approach has been conducted at LOF's Lathrop site on two previous occasions. First, in November of 1985, the RWQCB authorized LOF to treat approximately 200 cubic yards of soil contaminated with oil by land application. The contaminated soil contained approximately 34,000 ppm oil as reported by Woodward-Clyde Consultants in a correspondence dated, August 13, 1985. See Attachment II - Woodward-Clyde correspondence, dated August 13, 1985 and Attachment III - RWQCB authorization letter, dated November 7, 1986. The RWQCB authorized LOF to spread the contaminated soil in a one-half inch thick layer over an area of 2.3 acres. The contaminated soil was then incorporated into the existing soil by tilling. This was done to accelerate breakdown by increasing contact with naturally occurring soil microbes. Fertilizer was added to enhance treatment. Secondly, in March of 1986, the RWQCB authorized the treatment of an additional 60 cubic yards of material in the same manner. This authorization was made in an inspection report dated, March 28, 1986, See Attachment IV. Prior to application of the Soil, LOF proposes to conduct soil sampling and analysis at the area designated to receive the contaminated soil, for the purpose of establishing base-line soil parameters. Three months after the application of the Soil, LOF will conduct soil sampling at the applied area to determine the effectiveness of the land application treatment. Thereafter, LOF proposes to conduct soil sampling semi-annually until such time that the targeted cleanup levels have been met. LOF proposes to analyze the initial native soil samples and all subsequent area soil samples for; Motor Oil (TEPH-LUFT) Benzene (Method 8020) Kerosene Toluene " Diesel Ethyl Benzene " Xylene " Based upon LOF's understanding of the available risk appraisal techniques, which may be appropriately applied to this situation, LOF proposes to apply the General Risk Appraisal method described in the "Leaking Underground Fuel Tank Field Manual (LUFT)". By applying this method to LOF's contaminated soil and site condition situation, the resultant target cleanup levels are proposed; Diesel - 100 ppm, Toluene - 4 ppm, Xylene - 20 ppm and Ethylbenzene - 30 ppm. Documentation regarding the application of the General Risk Appraisal method to this situation and preliminary calculations are available upon request. LOF proposes to initiate the land application of the contaminated soil within twenty-four months of receiving approval to proceed from the RWQCB. LOF is requesting a twenty-four month window to commence, in order to address current property utilization issues associated with the 25- 30 acre application plot. LOF will maintain the soil at its current, secured location until initiation of the land application project. The soil has been placed on plastic sheeting, covered with plastic and secured by a tire lattice. The soil is located in a secure area which is not utilized by LOF.