SITE INFORMATION AND CORRESPONDENCE_FILE 1

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Ms. Wendy Cohen 19 December 1994 Page 2 All chromatographs of samples with detectable concentrations of TPH by Method 8015 will be submitted with the analytical results for review by the RWQCB-CV. Thus, the hydrocarbon range for the purgable compounds will be reported along with a quantification of the total extractable hydrocarbons. Additionally, CPL proposed that the following analytical methods be omitted from the MRP: Constituents Units Sample Test Method Sampling Preparation Frequency TPH as Gasoline mg/l 5040/50302 Modified 8015 Quarterly TPH as Kerosene mg/l 5040/50302 Modified 8015 Quarterly TPH as Diesel No. 2 mg/l 5040/50302 Modified 8015 Quarterly TPH as Diesel No. 4 mg/l 5040/50302 Modified 8015 Quarterly Total Recoverable mg/l 5520F/3513 EPA 418.1 Quarterly Petroleum Hydrocarbons Oil and Grease mg/l 5520B3 552013/664 Quarterly Total Lead mg/l 3020 7421 Quarterly 1. A chromatographic standard shall be developed for each constituent. 2. Purge and trap method used for sample preparation. 3. Extraction method used for sample preparation. These analyses should be omitted from the MRP because: • The petroleum hydrocarbons at the site have been fingerprinted as crude oil. • Standards used for quantifying TPH as gasoline, kerosene, and diesel no. 2 & 4 are not applicable, since these quantifications are reported as refined products. • Method 8015 Modified using a crude oil standard quantifies hydrocarbons from approximately C8 to C40, thus analysis by TPH as gasoline, kerosene, and diesel no. 2 & 4 would be redundant. • Methods 418.1 (TRPH) and 5520B/664 (O&G) are non analyte-specific analytical techniques susceptible to multiple positive interferences from non-petroleum sources. • Crude oil generally does not contain lead. Lead was a common additive to gasoline in the past, however, gasoline is not present at the Dividend site. Therefore, the analysis for total lead is not applicable to this project at this time. CPL will perform the next round of quarterly groundwater sampling upon your authorization (either verbal or written) of the proposed revisions to the MRP. It was stated in the cover letter to the DRAFT MRP that a work plan to evaluate the lateral and vertical extent of petroleum hydrocarbons in soil and groundwater is required. It is the position of CPL that both the lateral and vertical extent of hydrocarbon impacted soil and groundwater is defined on the Dividend Property. However, in order to adequately monitor the impact to groundwater at the site, CPL proposes the abandonment of groundwater