SITE INFORMATION AND CORRESPONDENCE_FILE 2

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Market Street, Stockton, the following reasons apply: 1) The sampler did not sign the chain of custody. 2) The sampler did not document, on the chain of custody, relinquishment to the laboratory. 3) The laboratory did not provide a signature upon receipt of the samples. 4) The transport of the samples to the laboratory took 6 days, during which time it is unknown who had possession of the samples and under what conditions they were held. Furthermore, although not included in the reasons stated above, one other issue raises concern for .PHS-EHD. The elapsed time between obtaining the samples and analyzing them was 13 days for both the March Lane site as well as the first set of sampling performed at the Police facility on 12/17/93 . Although the maximum holding time for benzene, toluene and xylene, under ideal temperature conditions, is 14 days, all 3 of the chains of custody in question give no indication of the conditions under which the samples were held, transported or received. Finally, EPA SW 846 states "The sample should be delivered to the laboratory for analysis as soon:: as practicable - - usually within 1 or 2 days after sampling" and that the chain of custody should contain, minimally, " . . .signature of collector. . . signature of persons involved in the chain- of possession. . . inclusive dates of possession. . . " . , I hope this information clarifies PHS-EHD' s rationale for not recognizing the referenced sample results. If you have additional questions regarding this issue, you can contact me at (209) 468- 3446. Ernest Fujimoto, M.D. , M.P.H. Acting Health Officer Doug Wilson, Supervising R.E.H.S. Environmental Health Division DW/pv:sd cc: Jim Giottonini, Public Works Director Epigene International _ Falcon Energy CVRWQCB - Gordon Boggs SWRCB - Terry Brazell