SITE INFORMATION AND CORRESPONDENCE

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V PUBLIC-HEALTH. SERVICES .Lie'r P SAN JOAQUIN COUNTY ENVIRONMENTAL HEALTH DIVISION ' I Ernest M. Fujimoto, M.D., M.P.H., Acting Health Officer ,445.N. San Joaquin Street. • P.O. Box 388 • 5tockton,'CA 95201-03$$ �4iiFOR�'�P (209) 468-3420 RIC NOTINI DIRECTOR OF ENVIRONMENTAL SERVICES CATELLUS DEVELOPMENT CORPORATION 201 MISSION STREET 30TH FLOOR LB ��!f SAN FRANCISCO CA 94105 RE: Catellus Development Property " " 4 r "" F SITE CODE: 1284 1325 West Weber Stockton CA .95203 . 'i San Joaquin County,Public Health Services,Environmental Health Division(PHS/EHD)has completed review of the ERM-West correspondence dated January 26, 1994 and has prepared`the following comments for your A consideration.- As background information,an excavation to remove contaminated soil was'initiated on October 5, 1993 and r was concluded on October 19, 1993. During this time numerous soil samples were collected and analyzed by t a mobil on-site laboratory,Transglobai Environmental Geochemistry.'(TEG),to verify that the contaminated soil was removed. On October 5, 1993, the first day the laboratory was onsite, PHS/EHD staff determined a that the laboratory was certified and that the appropriate equipment was available to perform the analysis. On October 19, 1993, the final day samples were collected, PHS/EHD staff was informed that the laboratory maybe using inappropriate analytical methodologies. Upon investigating the methodologies which were being used,PHS/EHD staff was informed by TEG chemists that instead of using EPA method 5030,purge and trap, they were utilizing a direct injection of a solvent extract for volatile hydrocarbon analysis. The method which was being used was described as a modification of EPA Method 3550 which'is used for non-volatile or semi- volatile analysis. The modification used freon as the extractant. PHS/EHD informed the laboratory that this methodology was inappropriate for volatile organic compounds and was informed that the method was used to reduce turn-around time and because ERM-West did not specify'that it'could not be used. ERM-West indicated that they felt that the soil sample results were valid atd that the information provided by TEG was adequate. TEG provided their rational for using the method;'to PHS/EHD, in correspondence dated November 29, 1993, which was based on Henry's Law constants. PHS/EHD subsequently informed ERM-West that the methodology was inappropriate and suggested that they,contact a chemist to explain why it was inappropriate. F PHS/EHD contacted the Central Valley Regional Water Quality Control Board (CVRWQCB) to discuss the modified methodology. The Tri Regional Board Staff Recommendations dated August 10, 1990 specify that for minimum verification analysis of volatile petroleum hydrocarbons soil samples are to be prepared using purge and trap and followed by analysis using EPA Method 8020. In order to respond to ERM-West's request for regulatory comments, PHS/EHD contacted the Department of Health Services, Environmental Lab Accreditation Program (ELAP). According to their records TEG is not approved to use a modified method for 8020. The two approvedpreparation methods for 8020 are purge and trap (5030) or direct injection (very limited application e.g., aqueous .process wastes). PHS/EHD then performed a method review of EPA SW846 which reiterated what PHS/EHD had already been informed by ELAP. r A Division oe.-an Joaquin County Health Care Services.