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STATE OF CALIFORNIA-Environmental Protectiotcy PETE WILSON Govem , <br /> CALIFORNIA REGIONAL WATER QUALITY CONTR ,, ?irjgL h <br /> CENTRAL VALLEY REGION T cF8V, FA/ r/1 <br /> 3443 <br /> 3443 Routier Road,Suite A -�-, <br /> Sacramento,CA 95827-3098 <br /> PHONE:(916)255-3000 13 ph 2, 03Vi <br /> FAX(916)2553015 <br /> gu, <br /> `a'4o.. <br /> a,�M <br /> 8 February 1995 <br /> Mr. Jon Weiss <br /> Libbey-Owens-Ford <br /> P. 0. Box 128 <br /> Lathrop, CA 95330 <br /> SOIL STOCKPILE AREA REMEDIATION,LIBBEY-OWENS-FORD COMPANY, <br /> SAN JOAQUIN COUNTY <br /> I have reviewed your 25 January 1995 letter which transmitted two sets of results of soil <br /> samples taken by Condor Earth Technologies (Condor), Inc. from the former location of the <br /> contaminated soil stockpile. My comments are presented below. <br /> 1. The results of each sampling event should be tabulated for ease of review. <br /> 2. The rationale for sample location and number was not presented in either of Condor's <br /> letters which transmitted the corresponding results of each sampling event. <br /> 3. In each sampling round, the four total extractable petroleum hydrocarbons samples <br /> from each of the four sections of the former stockpile area were composited into one <br /> sample resulting in four composite samples for approximately 6,000 square feet. <br /> Compositing soil samples to characterize or determine the extent of soil contamination <br /> is inappropriate because it results in dilution of the soil samples. A composite sample <br /> also makes identification of the origin of the contamination difficult since the <br /> composite sample is a mixture of several samples at different locations. Compositing <br /> soil samples is appropriate when characterizing a soil stockpile for treatment or <br /> disposal. <br /> 3. In each section, one sample was taken for testing of benzene, toluene, ethylbenzene, <br /> and xylenes (BTEX). Condor did not provide the rationale for selection of the sample <br /> tested for BTEX in each section. <br /> 4. As shown in the figure dated December 1994, the site in question is shaped like an "L" <br /> lying on its long side. The figure shows surface staining at the southeastern end of th-1 <br /> figure and at the western edge of the protruding portion of the figure. In spite of this, <br /> only one sample was taken from the Stained areas and this sample was not tested for <br /> BTE`i. <br />