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r44ec-6„lle-M <br /> GLMORANDUM <br /> CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD - CENTRAL VALLEY REGION <br /> 3443 Routier Road Phone: (916) 361-5600 <br /> Sacramento, CA 95827-3098 e ATSS: 8-495-5600 <br /> TO: Greg K. Vaughn FROM: Patricia Leary <br /> Senior Engineer Associate Engineer <br /> RCRA/TPCA Unit` RCRA/TPPA Unit <br /> DATE: 6 August 1987 SIGNATURE: <br /> SUBJECT: ARCADY OIL COMPANY, SITE CHARACTERIZATION WORK FOR TPCA <br /> Al Franks, consultant for Arcady Oil Company (AOC) , submitted a <br /> report dated 2 September 1985, regarding a preliminary site <br /> assessment of the AOC drilling mud disposal site. Ten monitoring <br /> wells and eleven soil borings were constructed as part of the <br /> investigation. Soil samples taken in three borings in the south <br /> area showed cobalt, lead, nickel, barium, and copper at hazardous <br /> levels (see map and table of values) , using the WET procedure. <br /> Based on these results, AOC was notified on 6 JAnuary 1987 that they <br /> were subject to the Toxic Pits Cleanup Act (TPCA) . On 9 March 1987 <br /> a meeting was held to discuss various regulatory programs, including <br /> the TPCA. Staff recommended that further waste characterization be <br /> conducted as soon as possible (but after notifying our office) , to <br /> verify or refute the preliminary results showing hazardous wastes <br /> were present at the site. <br /> In April 1987, Al Franks submitted a report regarding additional <br /> waste characterization completed at AOC. Six additional borings <br /> were drilled in the. vicinity of boring #11 (up to 20 feet north and <br /> 40 feet south) . Samples from a depth interval of six to nine feet <br /> were extracted using the WET procedure and analyzed for soluble lead <br /> content. Concentrations found were low, ranging from 0. 12 to 0.74 <br /> mg/1• <br /> The report does not provide adequate information to characterize the <br /> site under the TPCA program. My reasoning, and comments on the <br /> report, are as follows:- <br /> 1. The soil samples were only evaluated for lead content. Other <br /> constituents (copper, barium, cobalt, and nickel) were also <br /> previously found at hazardous concentrations and need further <br /> characterization to ® verify their presence and extent of <br /> contamination. <br /> 2. Additional samples should have been taken in the vicinity of the <br /> locations where any hazardous constituents were found, specifically <br /> borings #7 and #10. <br /> 3. The samples were only evaluated for soluble constituents, using <br /> the WET procedure. They 'should have also been evaluated for the <br />