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C A M B R I A <br /> March 3, 2004 <br /> Kagehiro Ranch, Inc. and Allied Insurance <br /> c/o Mr. D. Lee Hedgepeth <br /> 1300 K Street <br /> Modesto, California 95354 <br /> Mr.Michael Clevenger <br /> Pegasus Development <br /> 4900 Hopyard Road, Suite 202 <br /> Pleasanton, California 94588 <br /> Re: Comments to Draft Proposal/Workplan for <br /> Limited Soil Assessment <br /> © Country Flags Release, Spatafore Property <br /> 23577 Mountain House Parkway <br /> Tracy, California <br /> Dear Mr. Hedgepeth: <br /> On behalf of Chevron Pipe Line Company (CPL), Cambria Environmental Technology, Inc. <br /> (Cambria) has reviewed the December 22, 2003 Draft ProposaUWorkplan for a Limited Soil <br /> Assessment in response to the Country Flags Release. On December 4, 2003, approximately 750 <br /> barrels(31,500 gals.)of crude oil were released on property owned by Charles Spatafore at 23577 <br /> Mountain House Parkway, Tracy, California (the Site). The release occurred because an <br /> employee of Kagehiro Ranch, Inc., (a contractor to Mr. Spatafore) punctured CPL'S KLM crude <br /> oil pipeline while plowing the overlying fields. CPL'S emergency response activities recovered <br /> approximately 400 barrels of oil,and 350 barrels(14,700 gals.) are estimated to remain in the site <br /> subsurface. Kleinfelder has prepared the Workplan at the request of Mr. Kagehiro's insurer, <br /> Allied Insurance, and Pegasus MH Ventures I, LLC. <br /> To minimize project lifecycle costs and to accurately define the crude oil impact, Cambria offers <br /> the following comments to the Workplan: <br /> 1. The workplan proposes sampling following a grid pattern; however, no grid dimensions <br /> were specified. The Workplan figure did not include sample grids or sample locations. <br /> Cambria estimates that 50 ft x 50 ft grids sampled on center, would provide sufficient <br /> data to reasonably bracket clean-up costs. <br /> 2. The objectives of the proposed scope of work are to: 1) delineate the vertical extent of <br /> Cambria crude oil, and 2) pre-characterize soil for offsite disposal. In addition, the workplan <br /> Environmental <br /> Technology,Inc. proposes a methodology for collecting analytical data to support field observations of <br /> "clean"soil.Following any soil excavation, a minimum number of confirmation samples <br /> 5900 Hollis Street will be required, regardless of the pre-characterization results and observations of"clean" <br /> Suite A soil. <br /> Emeryville,CA 94608 <br /> Tel(510)420-0700 <br /> Fax(510)420-9170 <br />