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Mr. Jeff Johnson 0 -2 - . 18 November 2010 <br /> Mountain House Site#4 i <br /> Our comments are presented below. <br /> 1 . The Revised Work Plan is proposing to use a PID to screen soil samples but is <br /> basing sample selection for laboratory analysis on visual screening. Assuming the <br /> objective of sample screening is to identify the most contaminated soil samples for <br /> laboratory analysis, the PID is more suitable since it is a more reliable indicator of <br /> the presence of contamination than visual examination. <br /> 2. Page 6 of the Work Plan states that since tetraethyl lead (TEL) and tetramethyl lead <br /> (TML) are insoluble in groundwater, Chevron is no longer planning to submit <br /> groundwater samples for the speciated lead analyses that it had previously <br /> proposed in the Work Plan. Since there are numerous articles on the internet that <br /> document the presence of dissolved organic lead compounds in groundwater, <br /> including TEL and TML, this statement is unsubstantiated. Our rationale for <br /> requesting the organic lead analyses is to obtain data that would conclusively <br /> establish whether the groundwater contamination present at the Site originated from <br /> a petroleum transmission line that once contained leaded product versus lead from <br /> crude. Since the Kinder Morgan Pipeline (KMPL) was reportedly installed after the <br /> use of leaded fuel products was discontinued, it is unlikely that a plume containing <br /> lead would have originated from the KMPL. <br /> As an alternative to laboratory analysis for TEL and TML, Chevron may conduct <br /> laboratory analysis for dissolved lead during this sampling event. However, since <br /> there are other potential sources in the vicinity from which dissolved lead may have <br /> originated, the conclusive identification of a responsible party will require Chevron to <br /> return to the Site to obtain the more definitive groundwater data that can be only <br /> obtained from the speciated lead analyses. <br /> In order to achieve the goals of the investigation, please ensure that the comments <br /> presented above are incorporated into the sampling and laboratory analysis proposed in <br /> the Revised Work Plan. By 18 February 2011, please submit a report of the soil and <br /> groundwater investigation. <br /> If you have any questions regarding this letter, you may contact me at (916) 464-4811 <br /> or by email at betaylgAwaterboards.ca.gov. <br /> BRIAN TAYLOR, P.G. <br /> Engineering Geologist <br /> cc: Mr. Mike Infurna, San Joaquin County Environmental Health Department, Stockton <br /> Mr. Ken Yea, Kinder Morgan Energy Partners, Sacramento <br /> Mr. Steve Osborn, Kinder Morgan Energy Partners, Rocklin <br /> Mr. Rand Reynolds, Chevron Pipeline Company, Pittsburg <br /> Mr. Justin Sobieraj, SAIC, Oakland <br />