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William Stewart <br /> c/o Ben Curran <br /> October 31,1989 <br /> Page 2 <br /> 3.2.2 Geological Technics stated in their work plan that the necessary permits will be <br /> obtained before soil treatment is performed. The final decision on soil treatment will be <br /> made after the results of the composite sampling is performed. If motor oil is found to <br /> be of significant quantity,then aeration may not be the best method of treatment. <br /> 3.3 The rules and regulations set forth in RCRA do not cover petroleum waste. However, <br /> California law under Department of Health Services supervision does cover petroleum <br /> in their administrative codes and environmental protection laws. Appendix F of the <br /> LUFT Field Manual states that soil must have TPH values of 1000 mg/kg or greater to <br /> be classified as hazardous waste. Any soil containing less than that is not considered <br /> hazardous and,therefore,is not covered by DHS permitting requirements. However, <br /> the CJjX4TVWJit+e;Vqp&r4nent will be notified of our activity and,if they retire s_ <br /> permit, we will obtain it. _ <br /> 3.3.2 A permit will be obtained from the City of Tracy Waste Water Treatment Facility <br /> before the extracted ground water is released to the sanitary sewer. All required <br /> documents and lab data will be supplied. <br /> These comments should adequately address the concerns of the County and Regional Board. <br /> Other aspects of our work plan were found adequate,so we should be able to proceed with this <br /> project. The installation of the new tanks should be scheduled as soon as possible so that <br /> equipment can be ordered and the project set in motion. While the tanks and supplies are being <br /> obtained,Geological Technics will obtain the necessary permits from the City of Tracy and Air <br /> Pollution Control District. <br /> Ground Water Assessment <br /> Several comments were made by Tom Peltier of the RWQCB regarding the ground water <br /> assessment work plan-Phase II. However,at this time,only the comments regarding interim <br /> monitoring will be addressed in this addendum. If additional site characterization(monitoring <br /> well installation)is needed in the future,Geological Technics will submit another addendum <br /> addressing his concerns on well design,location,etc. <br /> Geological Technics concurs with the practice of performing multi-event ground water <br /> monitoring,before additional site characterization is performed. The following <br /> recommendations are made for interim monitoring of this site. <br /> The recommendations are: <br /> 1. To perform ground water level measurements and gradient calculations on a quarterly <br /> basis for one year. <br /> 2. To monitor ground water for the presence of petroleum hydrocarbons on a quarterly basis <br /> for a period of one year. The three existing wells will be purged by pumping a minimum <br /> of 5 well volumes before a sample is collected. One well volume is equivalent to the <br /> amount of water contained in the well casing and in the pore spaces of the filter pack. <br />