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GRAYCARY• TECHNOLOGY ' S LEGRL EDGE ' 401 B Street, Suite 2000 San Diego,CA 92101-4240 www.graycary.mm O] 619-699-4718 F] 619-699-2701 r'— October 29, 2001 OUR FILE NO.48387-78 Mr. Douglas Wilson Supervisor, REHS San Joaquin County Public Health Services r -. Environmental Health Division 304 E. Weber Avenue, Third Floor Stockton, CA 95202 Re: Helena Chemical Company—2245 West Charter Way, Stockton, CA Dear Mr. Wilson: This letter follows up on my letter of September 17, 2001 to Letitia Briggs and your follow-up conversations and communications with Helena's environmental consultant, George Donaldson of Geomatrix. I am enclosing the analytical laboratory results of the three plastic five-gallon containers noted in the August 17, 2001 inspection report, along with the results of the testing of the surface soil samples obtained by Mr. Donaldson. As Mr. Donaldson reported to you earlier this month, the three five-gallon plastic pails contained dried liquid fertilizer, and laboratory tests indicated that each container possessed the various nitrogen, phosphate, and potash mixtures consistent with that claim. The surface soil samples were tested for organophosphorus and organochlorine pesticides, heavy metals, TPHs, nitrates and TKN. No pesticides, organic chemicals or petroleum hydrocarbons were detected in any of the samples, and heavy metal concentrations were at background levels. Helena believes that the October 25, 2001 inspection of the facility has confirmed that virtually all of the items noted in the August 17, 2001 inspection have been addressed. Helena is working now on the labeling issue involving the five containers and the contingency plan issue noted in the October 25, 2001 inspection report, and will respond further on those issues within the time set forth in the inspection report. Helena is also providing the following additional information regarding the August 17, 2001 inspection report: • With respect to the items numbered 10, 19, 20 and 21, as noted above and in the September 17, 2001 letter to Ms. Briggs, the three five-gallon buckets contained fertilizer materials that were provided to customers for appropriate agronomic use shortly after the inspection, and were not hazardous waste. Accordingly, there were no violations of hazardous waste identification, labeling, storage or accumulation requirements with respect to the materials, and the materials were in any event promptly transferred from the site. SILICON VALLEY SAN DIEGO SAN DIEGO/GOLDEN TRIANGLE SAN FRANCISCO AUSTIN SEATTLE SACRAMENTO LA JOLLA