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MAY 1 9 X408` <br /> //PA EX ENM W4(HEARit 95610 <br /> E N V I R 0 T E C H , I N C . Phone 916.851.0174-• Fox 91 M1j 1n RY 0.242.5249 <br /> May 14, 2008 G <br /> Mr. Nuel Henderson <br /> San Joaquin County Environmental Health Department <br /> 304 East Weber Avenue, P floor <br /> Stockton, California 95201 <br /> Subject: Weed Oil Fortifiers Additional Information <br /> Moore Petroleum Bulk Plant ` <br /> 5491 F Street,Banta, California <br /> Apex Project No. ERA02.004 <br /> 4 <br /> Dear Mr. Henderson: <br /> Apex Envirotech, Inc. (Apex) has been authorized by Moore Petroleum (Moore) to <br /> provide this letter responding to the San Joaquin County Environmental Health <br /> Department (SJCEHD) letter dated March 10, 2008 (Appendix A) requesting additional <br /> information on the analytical suite to identify the suspected weed oil at the subject site <br /> (Figures. 1 and 2). <br /> This letter is based, in part,on information obtained by Apex from Moore, and is subject <br /> to modification as newly acquired information may warrant. <br /> WEED OIL <br /> Commercial weed oil was a special refinery fraction of petroleum based oil which <br /> contained higher portions of petroleum toxicants than normally present in oils refined for <br /> use as fuels. The percentage of compounds commonly used in weed oil as fortifiers <br /> (dinitro amyl phenol (DAP), dinitro butyl phenol (DBP), 2-sec, 4-butyl dinitrophenol <br /> (dinoseb), and pentachlorophenol (PCP)) are not known due to specific "brand" <br /> information not being available on the weed oil that was stored onsite. Based on a <br /> research paper on weed control in avocado orchards in California written in 1956 <br /> (included as Appendix B) diesel oils and other fuels deficient in aromatics can be made <br /> as toxic as desired by fortifying with such materials as oil-soluble dinitro (dinitro general <br /> herbicide) and PCP. Based on that information, the specific ratio of fortifying agents in <br /> weed oil cannot be determined. Even though a specific ratio cannot be determined, Apex <br /> has found that the fortifiers present in weed oil were used as a supplement, at a <br /> concentration high enough to be toxic to most weeds;but limited due to the cost of their <br />