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_ ' GE I VED <br /> • <br /> 1'��rhe �NOV 04 2014 <br /> ENGINEERING, LLC ENVIRONMENTAL HEALTH <br /> www.YorkeEngr.com PERMIT/SERVICES <br /> Ms. Kasey Foley October 31, 2014 <br /> Program Coordinator <br /> San Joaquin County Environmental Health Department <br /> 1868 East Hazelton Avenue <br /> Stockton, CA 95205 <br /> E-mail: KFolevC&,SJCEHD.com <br /> Subject: Sampling Plan for Pilkington North America Inc., 500 East Louise Avenue, <br /> Lathrop, CA; EPA ID#CAD005415633 <br /> Dear Ms. Foley: <br /> On behalf of Pilkington North America Inc., Lathrop facility (Pilkington), Yorke Engineering, <br /> LLC (Yorke) is submitting the attached outline for samples to be collected to close out the former <br /> Conditional Exemption waste treatment authorizations at the facility. This sampling summary is <br /> based on the October 28, 2014, site visit at the Pilkington facility. <br /> BACKGROUND <br /> The Pilkington facility formerly used an oil/water separator and a drum rinsing process for oil <br /> drums, both of which were hazardous waste treatment activities authorized under the Conditional <br /> Exemption Tier per California Health & Safety Code (H&SC) §25201.5. These treatment <br /> activities occurred on a concrete pad adjacent to the east side of the hazardous waste accumulation <br /> building. Even though the equipment was dismantled in 2011 and sent off-site to an appropriate <br /> destination facility, confirmation sampling was not performed. In addition to the equipment <br /> described above, an additional sampling area targeted was the bath basement (Lehr basement), <br /> where oil staining of concrete was observed. <br /> DISCUSSION <br /> H&SC §25201.5(d)(8)(A) requires the generator to remove or decontaminate all waste residues <br /> associated with the closure of a unit, including soils, as well as structures or equipment <br /> contaminated with hazardous waste from the unit. To verify that no hazardous waste residues <br /> remain, sampling will be performed as discussed with you during the October 28, 2014, site visit. <br /> This document identifies the proposed sampling methods, sampling locations, and analyses to be <br /> performed. Photos are provided to show sampling locations. <br /> SAMPLING PROCEDURES <br /> Waste Treatment Pad Samples <br /> Three sample locations have been selected in areas where there were cracks in the concrete that <br /> have been patched or where there is a concrete seam. Two sample locations are selected under the <br /> length of the former oil/water separator,and one was selected east of this area near where the drum <br /> rinsing may have occurred. <br /> LOS ANGELES/ORANGE COUNTY/RIVERSIDE/VENTURA/FRESNO/OAKLAND/BAKERS FIELD <br /> 31726 Rancho Viejo Road, Suite 218 ♦ San Juan Capistrano, CA 92675 ♦ Tel: (949) 248-8490 ♦ Fax: (949) 248-8499 <br />