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Table 1 Responses to March 24, 2004 Comments Chevron Bulk Fuel Terminal 1001621 22888 Kasson Road Banta,California Comments Responses 1 The Work Plan is proposing borings that are close to The boring locations were selected to confirm previous investigative results. A previous sample locations from a separate investigation. qualitative analysis of the data collected at the proposed boring locations will be Chevron needs to explain how sampling from these completed by a chromatogram expert. Due to significant safety and logistic concerns borings that are about 50 feet north of the pipeline will associated with underground utilities and vehicle traffic, collecting data adjacent to the determine whether there has been a release from the Chevron pipeline in West Grant Line Road would be difficult. SECOR will propose a pipeline and whether Chevron is collecting these samples more aggressive site assessment adjacent to the Chevron pipeline, If results of the to confirm previous investigative results. proposed site assessment indicate the presence of TPH as jet fuel. In the event that assessment adjacent to the pipeline becomes absolutely necessary, closure of multiple traffic lanes would be required. 2 The Work Plan does not discuss how deep the pipeline is The Chevron pipeline is located in the middle of West Grant Line Road, Tracy, Ca, at and whether sampling adjacent to the pipeline is feasible. approximately 9 feet below ground surface. Due to safety concerns, collecting data Chevron must include this information. adjacent to the Chevron pipeline in West Grant Line Road does not appear to be feasible at this time. 3 The Work Plan proposes to collect soil samples solely During soil boring activities, soil samples will be screened, through each 5-foot interval based on photoionization detector (PID) readings. for the presence of petroleum hydrocarbons. Screening with a photo-ionization detector Chevron does not discuss which soil samples will be and visual observations will allow for selection of discrete interval samples to be submitted for laboratory analysis if there are low or no analyzed. positive PID readings. The purpose of the investigation is to determine if there has been a release from the pipeline, A minimum of one shallow sample will be collected from the capillary fringe of each soil and therefore, Chevron needs to propose consistent boring regardless of the screening results. Positive screening results, suggesting that sampling for each of the borings on the depth of the pipeline, visual observation, and PID readings. hydrocarbons maybe present, will be used to select additional soil samples for laboratory analyses. Soil samples will be collected in a brass sleeve and submitted under a chain- of-custody record to a California State-certified laboratory for chemical analysis. 1:\Chevron\pi peline\2004ResponseToW orkplan.doc