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0 <br /> NNUDING A BETTER #NORAD <br /> December 29,2009 <br /> Ms. Wendy Cohen,P.E. <br /> Regional Water Quality Control Board <br /> 11020 Sun Center Drive #200 <br /> Rancho Cordova, CA 95670 <br /> SUBJECT: Mountain House Development Site #4 <br /> Byron Road, San Joaquin County, California <br /> Dear Ms. Cohen: <br /> This letter has been prepared on behalf of SFPP,LP operating partnership of Finder Morgan Energy <br /> Partners, LT (SFPP) for submittal to the Regional Water Quality Control Board, Central Valley <br /> Region (RWQCB). This document presents pertinent background information regarding the <br /> Mountain House Development Site #4 (the Site) located along Byron Road, San Joaquin County, <br /> California, and summarizes the technical rationale why SFPP does not believe the hydrocarbons <br /> previously detected at the Site warrant them authoring a work plan and/or performing a field <br /> investigation. The information and opinions presented within this document were discussed with <br /> RWQCB staff (Ms.Wendy Cohen and Mr. Brian Taylor) during a meeting held on <br /> December 17,2009. <br /> RWQCB REQUEST FOR A WORK PLAN <br /> In a letter dated October 23, 2009, the RWQCB requested that SFPP and Chevron Pipeline <br /> Company (Chevron) cooperatively submit a work plan for soil and groundwater investigation of the <br /> Mountain House Development #4 Site (RWQCB, 2009). This request letter postdated a notice and <br /> information request from the RWQCB in December 2008 (RWQCB, 2008), that both companies <br /> responded to in January 2009. MWH and SFPP understand the RWQCB issued the original letter <br /> and follow-on work plan request because of the presence of refined hydrocarbons in soil and <br /> groundwater at soil boring MH4-6, and the presence of buried petroleum pipelines operated by the <br /> parties for the transportation of refined fuels. <br /> The Site is one of six sites along this portion of Byron Road with hydrocarbons in soil and/or <br /> groundwater associated with a historic (no longer active) crude oil transmission pipeline known as <br /> the Old Valley Pipeline (OVP). Soil boring MH4-6 was completed near the northern edge of the <br /> Site in November 2005 by SAIC Inc. on behalf of Chevron Environmental Management Company <br /> (SAIC, 2006). SAIC had originally stated in the summary report for the investigation that the <br /> hydrocarbons in boring MH4-6 "appeared different from petroleum—affected soil' encountered in <br /> other Site borings, and conducted forensic tests on the soil sample collected from MH4-6 at 8 feet <br /> below ground surface to evaluate its characteristics (SAIC, 2006). The RWQCB summarized the <br /> fingerprinting results in the October 23, 2009 letter as indicating "a combination of weathered <br /> kerosene, heating fuel, diesel, and jet fuel" (RWQCB, 2009). The actual Chevron fingerprint report <br /> described the sample as containing"hydrocarbon as in the jet fuel boiling range...carbon range from <br /> 2129 H.Cali9omia Blvd, TEL 925 627 4500 <br /> Suite 61. FAX 925 627 4501 <br /> Wahkit Creak,CA 94596 w1hwm,vhglobal=.m <br />