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ir w� k" K L E I N F E L D E R October 23, 1989 :.a L ` F ! File: 24-2058-3 N 0 V ';' 8 1989 Ms. Linda Steiger ENVIRONMENTAL HEALTH- Sacramento Equipment Maintenance, Inc. PERMIT/SERVICES 25 Connie Drive Sacramento, CA 95815 SUBJECT: Soil Remediation Work Plan AT&T Lodi Facility Dear Ms. Steiger: Enclosed are copies of Kleinfelder's Soil Remediation Work Plan dated September 16, 1987, for the remediation of diesel contaminated soil from the AT&T microwave site at 157 West Turner Avenue in Lodi, California. Also enclosed are a letter from the Regional Water Quality Control Board (RWQCB) dated October 6, 1987, and Kleinfelder's cover letter report dated October 26, 1987. jDuring the removal of four underground diesel storage tanks, approximately 400 cubic ' yards of backfill material and native soil were excavated and stockpiled on site' Soil samples collected from the stockpiled soil had total petroleum hydrocarbon ':'(TPH) concentrations as diesel of 220, 430, 440, and 1,100 mg/kg. Kleinfelder prepared the enclosed work plan to transport the soil to Forward Landfill in Stockton and aerated the soil for disposal in the'landfill. The work plan was submitted to the RWQCB and the San Joaquin Local Health District (SJLHD) for their review and comment. The RWQCB stated in their letter that soil over 1,000 mg/kg could .not be transported to Forward and suggested that the area of the stockpiled soil With a concentration greater than 1,000 mg/kg be resanpled. If the TPH concentration was less a than 1000 mg/ g, the soil could be sent to Forward for aeration. 'I Kleinfelder segregated the soil pile and sent the soil with concentrations below 1000 f mg/kg i to Forward for aeration and moved the remaining soil onto new plastic. A composite soil sample was collected from the stockpiled soil which previously had a TPH concentration greater than 1,000 mg/kg, and the composite soil sample had a TPH concentration's of 400 mg/kg. The 400 mg kg concentration was more representative of the rest of the soil pile, and the 1,100 mg/kg concentration may have been an isolated occurrence. Additionally, moving the soil to new plastic may have mixed and further aerated the soil. With the results of the composite sample, the rest of the soil pile was transported to Forward for I aeration. The results of the soil aeration were presented in Kleinfelder's Soil Remediation Report dated May 9, 1988. The soil remediation work plan and report were submitted to the RWQCB andthe SJLHD. Both agencies verbally approved the work plan and results of Kleinfelder's October 26, 1987 letter. Only the RWQCB provided written correspondence. A hazardous waste manifest was not required for transporting of soil to Forward Landfill because the j soil was documented with the analytical results of the soil samples to be below 1,000 mg/kg KLEINFELDER 9795 Business Park Drive, Sacramento, CA 95827 (916) 366-1701 i :i