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` Mr.John Moody September 15, 1995 Page 2 Metals It is CPL's contention that analyses for metals are not applicable for the complete characterization of the subject site. The RWQCB requested that soil samples "should be analyzed for total and soluble methods using the waste extraction test using deionized water as the extractant." CPL assumes this is in reference to the analysis of CAM Title 22 Metals using EPA Methods 6010/7000. It should be noted that these analyses are utilized to determine whether a material is a hazardous waste as defined by the California Code of Regulations, Title 22, Division 4, Chapter 30, Article 11; however, due to a lack of other criteria, the CAM criteria are commonly used as a framework to discuss metal concentrations. The analysis of soils for metals should be omitted from the sampling protocol because: • As described in EMCON's addendum letter, the concentrations of metals in petroleum hydrocarbon impacted soils at the site have been evaluated and are within background levels in the area. • Previous sampling for total metals from"discolored soil excavated during the removal of the viscous oil/gravel area(Area 7)..." which contained "the least weathered soil contaminant..." (Raney Geotechnical, 1995) have exhibited metal concentrations less than the action levels referenced in Title 22. • Background levels of metals in crude oil are insignificant; therefore, the transportation of crude oil via pipelines does not present a significant source of metals. Metals traditionally associated with crude oil are nickel (Ni) and vanadium (V). These metals are typically complexed with organic compounds called porphyrins. A study was conducted by Chevron Research and Technology (CRTC) between 1973 and 1980 in which the concentrations of Ni and V were evaluated in of 32 crude oils from the San Joaquin Valley (SJV). SJV crude oil was transported in the pipeline formerly on the subject site via the Standard Oil Company's Old Valley Line. The results of this study indicated that average total concentrations of Ni and V in SJV crude oil are 41 and 33 ppm, respectively. These levels are well below the total threshold limit concentration(TTLC) levels for both Ni (2000 ppm) and Vanadium(2400 ppm), as referenced in Title 22. The low concentrations of Ni and V in petroleum impacted soils from the site(Raney Geotechnical, 1995) shows these metals have not accumulated at the site. The RWQCB has also mentioned that chromium may be associated with oil operations. Chromium is not associated with the pipelining of crude oil. Chromium is most commonly used as a biocide/antioxidant in cooling tower process water. Therefore, CPL requests the analysis of metals be omitted from future CPL sites associated with the former Old Valley Line crude oil pipeline.