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A=COM <br /> storage areas and other places on Site where foams were/may have been released(e.g., the truck <br /> rack and AS Ts in the West Terminal and the railcar offloading rack in the East Annex). <br /> Response: Stormwater sampling locations have been added for the West Terminal and East Annex. <br /> West Terminal stormwater samples will be collected from control points at the northwest and <br /> southwest entry gates (Figure 3). Stormwater samples will be collected prior to discharge. A <br /> stormwater sample will be collected at the East Annex from the lined stormwater secondary <br /> containment area (Figure 4). The containment is discharged via piping west to Stork Road and then <br /> north to West Washington Street. The sample will be collected during discharge prior to leaving the <br /> site. <br /> Comment 6:Appendix A, Section 1 of the Work Plan provides reporting limits (RLs) but not method <br /> detection limits (MDLs) for the PFAS analytes. Additionally, the Work Plan provides no RLs or MDLs <br /> for the general chemistry and metal analytes listed in Table 4.1 of Appendix A. Please add those <br /> missing items to the Work Plan. For the general chemistry and metal analytes, please include <br /> justifications for the proposed RLs (e.g., historical or current analyte concentrations at or near the <br /> Site). <br /> Response: Attached Table 1 provides the MDLs for PFAS analytes. The RLs and MDLs for general <br /> chemistry and metal analytes are provided in Table 2, attached to this response. These RLs and <br /> MDLs were provided by Eurofins Sacramento, which is the analytical laboratory that will be utilized for <br /> the PFAS analysis. The RLs are determined according to Section 6.6 of the Eurofins SOP NDSC-QA- <br /> SOP42091. The SOP is included as Attachment B. <br /> Comment 7: Appendix A of the Work Plan does not state whether the field parameters listed in Table <br /> 2 of Attachment 2 to the Order will be collected for groundwater samples. Please revise the Work Plan <br /> to include measurement of those parameters during groundwater sampling activities. <br /> Response: As required by Order WQ 2021-0006-DWQ (California Water Boards, 2021), field <br /> parameters will include depth to water, temperature, electrical conductivity, pH, and turbidity collected <br /> during groundwater sampling. No other field screening, confirmation, or split samples will be required <br /> for this sampling. <br /> Comment 8:Appendix A, Section 9 of the Work Plan indicates field blanks will be collected at 1 per <br /> 20 samples per matrix or one per week per matrix. The Central Valley Water Board staff strongly <br /> recommend that Tesoro Logistics revise the frequency to 1 per 20 samples per matrix or 1 per day, <br /> whichever is greater, to evaluate the effects of potential environmental sources of cross-contamination <br /> (e.g., wind patterns) on a daily basis. <br /> Response: As requested by CVRWQCB field blanks will be collected at a rate of one per 20 field <br /> samples, or one field blank per day, whichever is greater, for the full analytical suite. <br /> Comment 9:Appendix A, Section 9 of the Work Plan indicates equipment rinsates will be collected at <br /> 1 per 20 samples or one per week. The Central Valley Water Board staff strongly recommend that <br /> Tesoro Logistics revise the frequency to 1 per day per type of non-dedicated equipment to ensure all <br /> kinds of non-dedicated equipment used during the investigation are evaluated for potential cross- <br /> contamination. <br /> Response: As requested by CVRWQCB equipment blanks will be collected at a rate of one per day <br /> per type of non-dedicated equipment for the full analytical suite. <br /> Comment 10: The Work Plan does not include the Perjury Statement required by Section V. of the <br /> Order. Please include the Perjury Statement signed by a duly authorized representative. <br /> Response: In response to Comment 10, the Perjury Statement is included below. The submitted <br /> statement applies to the PFAS Work Plan submitted August 31, 2021 and to the responses included <br /> in this letter. <br /> aecom.com <br /> 3/5 <br />