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Mr. Jeff Cosgray and Ken - 2 - 24 August 2010 <br /> Mountain House Site#4 0 <br /> both borings were collected adjacent to the BAPL. Chevron had previously concluded <br /> that soil and groundwater samples collected from adjacent borings laterally delineate <br /> the spill to a localized area and indicate that the hydrocarbons were not released from <br /> the BAPL. <br /> KMEP submitted the 29 December 2009 Mountain House Development Site #4, Byron <br /> Road, San Joaquin County, California, which includes photos of the Site verifying that <br /> the MH4-6 was advanced eight feet from the BAPL and 20 feet from the KMEP pipeline <br /> (KPL). Illustrations presented to us during a 7 December 2009 meeting with KMEP <br /> indicate that groundwater flows from Chevron's assets toward KMEP's. Thus, KMEP <br /> does not believe the contaminants found at MI-14-6 could have originated from the KPL, <br /> so additional investigation on its part is not warranted. <br /> Our comment is presented below. <br /> Neither Chevron's nor KMEP's claims that their respective pipelines were not sources <br /> for the contamination found in MI-14-6 can presently be verified with existing data <br /> because (1) the scope of Chevron's 2005 investigation did not result in defining the <br /> extent of the refined fuel found at MH4-6, and (2) as discussed in comment No. 3 of our <br /> 18 March 2010 letter and during the 6 May meeting, laboratory analysis for temporal <br /> fuel components such as tetraethyl lead, tetramethyl lead, and the lead scavengers <br /> ethylene dibromide and ethylene dichloride has never been conducted on samples <br /> collected from the Site. <br /> To address these data gaps, Chevron needs to submit a work plan to conduct a <br /> groundwater investigation. The objective of the investigation is to determine the extent <br /> of the petroleum constituents found in MH4-6. The sampling and analysis plan must <br /> include analysis for organic lead or lead scavengers, which could help determine the <br /> relative age, type, and origin of fuel related compounds encountered during the <br /> investigation. <br /> By 24 September 2010, Chevron must submit a work plan to conduct a groundwater <br /> investigation to determine the extent of petroleum hydrocarbons in groundwater in the <br /> vicinity of boring MI-14-6. <br /> If you have any questions regarding this letter, you may contact me at (916) 464-4811 <br /> or by email at beta ror@waterboards.ca.gov. <br /> i <br /> BRIAN TAYLOR, P.G. <br /> Engineering Geologist <br /> CC' Mr. Mike Infurna, San Joaquin County Environmental Health Department, <br /> Stockton <br /> Mr. Steve Osborn, Kinder Morgan Energy Partners, Rocklin <br /> Mr. Rand Reynolds, Chevron Pipeline Company, Pittsburg <br />