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Mr Donald Kirk Page S ISeptember 22, 1997 . of California Primary MCLS are human health risk-based values established for water continually used for drinking or culinary purposes In using these ' comparisons, it is important to consider two factors First, as noted above, is that the ground water grab samples were not filtered prior to analysis Additionally, ' ground water beneath the site is not necessarily a potential drinking water supply It follows that comparison of these sample results to drinking water standards may not be applicable. This comparison is presented herein because it ' is one typically made by regulatory agencies (the RWQCB, in particular) as a point of departure evaluation It is noted that there are no applicable MCLs for TPH compounds The results presented for ground water samples in Table 2 indicate that benzene, ethylbenzene, and total xylene concentrations in samples collected downgradient ' of both UST locations exceed their respective MCLs TPH as gasoline (or degraded gasoline) was detected in ground water samples UST1N, UST2N, and FS3 Unknown hydrocarbons in the diesel and/or motor oil range were detected ' in the same three samples The highest concentrations of TPH (460,000 ppb gasoline, and 430,000 ppb unknown diesel/motor oil range) were detected in t sample UST1N The highest concentration of benzene occurred in sample UST2N (1,600 ppb), although sample UST1N had the highest concentration of all the BTEX constituents combined (27,350 ppb) CONCLUSIONS AND RECOMMENDATIONS Based on site reconnaissance, personnel interviews and limited soil and ground ' water investigation associated with the Phase II ESA, the following are ERM's conclusions regarding the areas investigated at the Heinz Tracy Factory ' • There appear to be USTs at the two locations investigated Although geophysical methods could not confirm the exact location, size, or orientation of the tanks, visual evidence such as possible fill or vent pipes combined with ' employee reports and grab soil and ground water sampling results strongly indicate the presence of USTs at these locations ' 0 Laboratory analytical results indicate that soils in the area north of the Forklift Shop have been impacted by petroleum hydrocarbons in the diesel and/or motor oil range, and that soils and ground water in the UST1 and ' UST2 locations, as well as the area south of the Forklift Shop, have been impacted by petroleum hydrocarbons as gasoline or degraded gasoline plus ' selected VOCs • • Recognizing the exceedances of potentially applicable regulatory standards ' (industrial soil PBGs and California Primary Drinking Water MCLs) for TPH 1