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0 0 <br /> V COMPLIANCE/ENGINEERING/REMEDIATION LT620 NWRlentaermc <br /> 6620 NW 38th Terrace <br /> Gainesville,Florida 32653 <br /> T 352.371.1770/F 352.377.6482 <br /> October 2, 2014 <br /> Mr. Jeffrey D. Mann,P.G. <br /> National Oilwell Varco <br /> 7909 Parkwood Circle Drive <br /> Houston, Texas 77036 <br /> RE: Verti-cast Area Environmental Assessment <br /> NOV Ameron Water Transmission Pipe Facility <br /> 10100 West Linne Road, Tracy,California <br /> Dear Mr. Mann: <br /> In August 2014 LT Environmental, Inc. (LTE), under contract to National Oilwell Varco LP <br /> (NOV), conducted an environmental assessment of the verti-cast area of the NOV Ameron water <br /> transmission pipe manufacturing facility located in Tracy, California (Figure 1). The purpose of <br /> this assessment was to determine the horizontal and vertical extent of form oil residue in the soils <br /> surrounding the verti-cast area. <br /> In the verti-cast pipe fabrication area, form oil is utilized to separate cast concrete pipe sections <br /> from steel forms.NOV Ameron personnel confirmed with LTE that the form oil product utilized <br /> in the verti-cast area is RO-396TM Release Agent, which is mineral-oil based. Mineral oil has a <br /> very low toxicity, and is not regulated under federal or state rules. During the previous limited <br /> assessment conducted in February 2014, laboratory analysis of the soil samples collected in the <br /> verti-cast area indicated that the residue detected exhibited a hydrocarbon signature of mineral <br /> oil consistent with the information provided by NOV Ameron personnel. Therefore, in a scope of <br /> work provided to NOV on June 26, 2014, LTE proposed the collection shallow soil samples at <br /> up to 12 locations in the verti-cast area to be submitted for laboratory analysis of mineral oil by <br /> United States Environmental Protection Agency(EPA)Method Solid Waste (SW) 8015M. <br /> Verti-Cast/Form Oil Usaee Area <br /> On August 20, 2014, LTE collected 19 discrete soil samples from 12 soil borings advanced <br /> through soil and fill material adjacent to the concrete pads in the verti-cast area,using a direct <br /> push drill rig(Figure 2). Soils in the verti-cast area consisted mainly of silty to sandy fill material <br /> and railroad spur ballast rock and occasional fine gravels. The soil boring logs are attached as <br /> Attachment A. The sample locations were based on surface staining observed at the time of the <br /> investigation and information provided by NOV Ameron regarding the amount of casting <br /> completed in the northern portion of the verti-cast area. <br /> The soil borings ranged in total depth from 1 foot below ground surface (bgs) to 10 feet bgs <br /> based on apparent odors, visual observations, and organic vapor concentrations as measured by a <br /> photoionization detector(PID). PID readings were highest in the upper 3 feet of the soil column <br /> and ranged from 69.1 parts per million (ppm; SB05 at 2.5 feet bgs)to 340 ppm (SB06 at 2.5 feet <br />