SITE INFORMATION AND CORRESPONDENCE

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PFTF WII SON f:nvwr ,;TQ En RN-C F 1 P t CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD - CENTRAL VALLEY REGION i; i° i ii i ll_TI I p 3443 Routier Road, Suite A Sacramento, CA 95827-3098 -" PHONE: (916) 255-3000 p FAX: (916) 255-3015 9'-I FEB 14 PI�q i 2: 45- 11 February 1994 Mr. D. O. Culbertson Chevron Pipe Line Company — 5080 California Ave., Suite 400 Bakersfield, CA 93309-1671 WORK PLAN FOR ADDITIONAL SITE INVESTIGATION, CHEVRON PIPE LINE COMPANY, FORMER LYOTH LOADING STATION, TRACY, SAN JOAQUIN COUNTY We have reviewed the 21 December 1993 work plan, prepared by your consultant EMCON, for the above-referenced site. I have the following comments. 1. In the cover letter, Mr. Doug Christian of Chevron Pipe Line Company, stated that the work plan would be implemented after our approval and after execution of a remediation agreement between Chevron and the property owners, the Hoffmans. In a 31 January 1994 phone conversation, Mr. Ronald Hoffman said that Chevron had not yet sent him a proposed remediation agreement. This is troubling since Mr. Christian gave us the impression last fall that this agreement was drafted and would be sent to the Hoffmans in December. We need a proposed date for executing this remediation agreement and beginning investigation work. 2. On page 4, the work plan states that soil and ground water samples will be analyzed for total petroleum hydrocarbons as diesel (TPH-D) and benzene, toluene, ethylbenzene, and xylene (BTEX) using EPA Method 8020. Our staff chemist has said that this method is inadequate because the contamination comes from a heavy fuel oil. The following test methods should be used to test all soil and ground water samples at this site: EPA Method 8020 for BTEX, EPA Method 8015M for TPH-D and total recoverable petroleum hydrocarbons (TRPH), and EPA Method 8270 for semi-volatile organics, including polynuclear aromatic hydrocarbons. 3. Also on page 4,'the work plan states that soil samples will be collected from the borings at a minimum of 5-foot intervals for lithologic information. We would like continuous cores in the three proposed monitoring wells for lithologic and stratigraphic correlation. In the original investigation in 1991, six boreholes and two monitoring wells were drilled, but only interval sampling was done for lithologic identification, none had continuous cores. 4. A rationale is needed for the 0.02-inch slotted casing and #3 graded sand filter pack that are proposed.