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STATE OF CALIFORNIA—HEALTH AND WELFARE AGENCY <br /> GEORGE DEURMEIIAN, Govrmor <br /> DEPARTMENT OF HEALTH SERVICES <br /> TOXIC SUBSTANCES CONTROL DIVISION APR 21 1989 <br /> REGION I pi,+ <br /> 4250 POWER INN ROAD ENVIROfdPAEN AL HEALTH <br /> SACRAMENTO,CA 95826 {HERMIT /SERVICES <br /> (916)739-3145 <br /> April 19, 1989 <br /> Mr. Jeff Ludlow <br /> Harding Lawson Associates <br /> 10324 Placer Lane <br /> Sacramento, CA 95827 <br /> Dear Mr. Ludlow: <br /> BECK DEVELOPMENT SITE, TRACY, SAN JOAQUIN COUNTY <br /> On March 11, 1989, the Department received a work plan by <br /> Harding Lawson Associates titled, "Site Characterization Work <br /> Plan, Schulte Road Extension, Tracy, California. " The work <br /> plan describes characterization activities to be conducted on <br /> the Beck Development property concerning the proposed <br /> construction of a road and drainage channel . These <br /> construction activities will be under the direction of the <br /> City of Tracy. The San Joaquin County Local Health District <br /> referred the work plan to the Department of Health Services <br /> for review. <br /> In a letter to Mr. Craig Phillips dated November 14 , 1988, <br /> Mr. James Tjosvold of the Department of Health Services stated <br /> that the Department only has jurisdiction in the area of <br /> hazardous waste control laws and regulations and not general <br /> approval of public works projects. The only area in which the <br /> Department has jurisdiction would be concerning the excavation <br /> and off site disposal of contaminated soil associated with the <br /> former oil storage tank on the Beck property. If contaminated <br /> soils are going to be disposed of off site, then they must be <br /> evaluated as to their toxic and hazardous nature as specified <br /> in the California Code of Regulations, Title 22 , Division 4, <br /> Article 11. If contaminated soils are found to be hazardous <br /> by these criteria, then they must be disposed of at a Class I <br /> landfill. <br /> We have reviewed the work plan for the proposed <br /> characterization activities to be conducted at the site and <br /> our comments are: <br /> 1. The purpose of the work plan is not clearly stated. If <br /> the work plan's purpose is to characterize soils to be <br /> excavated and disposed of, then requirements stated above <br />