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Kennedy/Jenks Consultants <br /> • <br /> Based on these results, an additional 14 surface soil samples (SS-1 to SS-14) were collected in <br /> the vicinity of Well MW-1 and analyzed for total lead (IC 1992b). The goal of this effort was to <br /> delineate the extent of lead at concentrations greater than a proposed action level of 500 mg/kg <br /> ' (the project files contain no record that approval of this goal was sought from the Regional <br /> Water Quality Control Board [Regional Board] or DTSC). Lead was detected at concentrations <br /> ranging from 120 to 1,600 mg/kg, and it was concluded that additional sampling would be <br /> required to characterize the extent of the lead. <br /> As a result, a more comprehensive investigation was undertaken, as detailed in the Soil <br /> Sampling Workplan (IC 1993a). The workplan, which was reported by IC to have received <br /> verbal approval from the Regional Board, proposed to overlay a 150-foot by 150-foot grid on <br /> OU-1 to determine locations for 36 surface soil samples (sample depths of 0.5 to 1.0 feet bgs) <br /> (S-1 to S-36) and nine shallow boring locations for collection of surface soil samples and <br /> underlying soil samples (1.0 to 1.5 feet and 1.5 to 2.0 feet bgs). All samples were analyzed for <br /> total lead only. Concentrations of lead ranged from 5.3 to 3,120 mg/kg in the surface samples; <br /> 10.6 to 3,520 mg/kg in the mid-boring samples; and 7.4 to 882 mg/kg in the deepest samples. <br /> Using these data, the volumes of soil onsite with lead concentrations above possible action <br /> levels of 1,000 mg/kg, 500 mg/kg and 174 mg/kg were estimated at 1,500, 3,500 and 9,500 cy, <br /> respectively. <br /> At the request of Southern Pacific, IC conducted a risk assessment, as summarized in the <br /> report, Derivation of a Soil Action Level for Lead(IC 1993b). Using the lead exposure model <br /> developed by DTSC, as described in DTSC's 1992 document entitled Assessment of Health <br /> Risks from Inorganic Lead in Soil— Supplemental Guidance for Human Health Multimedia Risk <br /> Assessments of Hazardous Waste Sites and Permitted Facilities, action levels for residual lead <br /> in soil were determined based on the most conservative (protective) assumptions for future land <br /> use, including residential use of the property, children as receptors, and children's consumption <br /> of home-grown produce. The result was a mean soil action level for lead of 241 mg/kg. <br /> The risk assessment results were transmitted to the Regional Board as an attachment to the <br /> Workplan for Further Site Characterization (IC 1993c). This workplan indicated that Southern <br /> Pacific was seeking approval from the City of Tracy (City) Planning Department for <br /> 1 redevelopment of the Railyard, and the City required concurrence from the San Joaquin County <br /> Public Health Services (County) that site conditions were acceptable for residential use. The <br /> County in turn requested approval from the Regional Board. As a result, Southern Pacific <br /> prepared the workplan for the Regional Board identifying steps necessary to fully characterize <br /> site soils, exposure risk due to soils, groundwater quality, and potential for soil constituents to <br /> impact groundwater quality. Potential remedies to address any impacts would then be <br /> evaluated, and the preferred and approved remedy would be implemented. The workplan noted <br /> which steps had been completed to date and defined tasks to resolve the remaining data gaps <br /> in the characterization. The workplan also indicated that Southern Pacific would remove the soil <br /> containing lead at concentrations above the Title 22 Total Threshold Limit Concentration (TTLC) <br /> of 1,000 mg/kg. <br /> The Regional Board provided comments on the workplan, including a request that the <br /> 241 mg/kg soil action level for total lead be used. IC responded on behalf of Southern Pacific <br /> . that the value derived with DTSC's lead exposure model was overly conservative for use as the <br /> remediation goal, and the 500 mg/kg goal was more appropriate (IC 1994x). The Regional <br /> Board then agreed to provide conditional approval of the workplan, contingent upon DTSC's <br /> DRAFT Phase I Remedial Investigation Report Page 4 <br /> Former Tracy Railyard, Tracy, California <br /> g:lis-group\admin\jobk0510565777.18—uprr\09-reportslri rplllext.doc <br />