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STATE OF CALIFORNIA-HEALTH AND WELFARE AGENCY GEORGE DEUKMEJIAN, G,., DEPARTMENT OF HEALTH SERVICES TOXIC SUBSTANCES CONTROL DIVISION REGION 1 4250POWER INN ROAD SACRAMENTO,CA 95826 November 22 , 1988 (916)7393145 Mr. Fred Baumbach Valley Industries, Inc. 1313 South Stockton Street Lodi, CA 95240 Dear Mr. Baumbach: RE: SOIL SAMPLING PLAN FOR VALLEY INDUSTRIES, INC. We have reviewed the Soil Sampling Plan for Valley Industries, Inc. submitted on September 26, 1988 . Although the workplan is generally acceptable for a site assessment of this size, we have some concerns regarding the background sampling. We are concerned that one background sample will not be sufficient to adequately define "uncontaminated " conditions and suggest that the proposal to obtain only one background sample be re-evaluated. In investigations of this small size, we utilize background sample results to make a determination regarding the extent of any contamination and also to aid in determining appropriate clean-up levels. One background sample does not provide sufficient data to make these determinations. By obtaining only one background sample, there is also a risk that results will be unnaturally high or low which will then bias subsequent determinations. Consideration also needs to be given to the location of the background samples. Background samples are generally taken off-site at a location free from any potential influence of contamination. In similar circumstances where we have provided oversight of small clean-ups, we have required three background samples be obtained from locations off-site of the facility. In this situation, we suggest that one on-site and two off-site background samples be collected at all three depth intervals indicated in your plan and that initially only the surface intervals be analyzed. So as not to hold up progress any longer, and assuming our suggestion will be incorporated, please consider your plan approved.