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Following tank excavation, two soil samples were collected from the pit where the waste oil tank had been located. Analyses indicated the presence of lead up to 25 mg/kg in soils beneath the former tank. (2) An unknown quantity of soil and concrete excavated from the underground storage tank area was deposited in the northeast corner of the trailer park on site(19). 3.4.2 Soil and Air Targets. Approximately 40 people reside in the trailer park on site, and two others are employed by the current business (5,11,36). Tracy Joint Union High School is less than 200 feet from the north side of the site and has a student population of approximately 1,750(37). However, the Cox & Cox site and Tracy Joint Union High School are separated by an alley and a fence that restrict students and passersby from accessing the site (8). The residential population within 2 miles of the site is estimated to be 1,463 people (38). There are no daycare centers on or within 200 feet of the site (5). 3.4.3 Soil and Air Pathway Conclusions. Lead was detected at a maximum concentration of 25 mg/kg in onsite soil samples collected from the excavation pit of a former waste oil storage tank(2). An unknown quantity of soil and concrete from this excavation area was deposited in the northeast corner of the residential trailer park on site, where it remains uncontained (19). Approximately 42 people either reside on site or are employed on site (5,11,36). The Tracy Joint Union High School is within 200 feet of the site and has a population of approximately 1,750 students(37). 4.0 EMERGENCY RESPONSE CONSIDERATIONS The National Contingency Plan [40 CFR 300.415 (b) (2)] authorizes the EPA to consider emergency response actions at those sites that pose an imminent threat to human health or the environment. For the following reasons, a referral to Region IX's Emergency Response Section does not appear to be necessary: • The majority of the site is fenced,restricting access to passersby. • Hazardous substances generated by onsite operations are removed and disposed of off site approximately once every 3 months by a licensed hazardous waste hauler. 5.0 SUMMARY The Cox and Cox Property site occupies 5072, 595, and 599 East Eleventh St. in Tracy, San Joaquin County, Calif. The site is in a relatively flat, commercial area of Tracy and consists of a 1.4-acre lot occupied by Mr. Ed's Mufflers and Brakes at 595 East Eleventh St., a residential trailer park at 5072 East Eleventh St., and a vacant building at 599 East Eleventh St. The site is bordered on the north by an unpaved alley across from Tracy Joint Union High School, on the south by Eleventh Street, on the west by the Cox Brothers' Firestone tire service, and on the east by a vacant dirt lot. The perimeter of the site is fenced, except for the south side along Eleventh Street. From 1938 to 1984, the site operated as a service station. The trailer park has been on site since 1938. Mr. Ed's Mufflers and Brakes, the current business tenant on site, has been in operation since approximately 1986. The waste management practices on site prior to 1956 are not known. • PA Cox& Cox-BB•9193 8 Printed on W%recyded Paper.