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t <br /> Chevron <br /> Chevron <br /> 1: C. <br /> September 15, 1995 Chevron Pipe Line Company <br /> 4000 Executive Parkway,Suite 400 <br /> San Ramon,CA 94583 <br /> P.O.Box 5059 <br /> San Ramon,CA 94583-0959 <br /> D.0.Culbertson <br /> Mr. John Moody Site Remediation Specialist <br /> California Regional Water Quality Control Board (510)842-6930 <br /> Central Valley Region <br /> 3443 Routier Road, Suite A <br /> Sacramento, California 95872-3098 <br /> Work Plan Revisions <br /> Mt. View Townhomes <br /> Old Valley Line Mile Post 215 <br /> Tracy, California <br /> Dear Mr. Moody: <br /> Please find attached EMCON's Addendum to Work Plan for Site Assessment, Old Valley Line, <br /> Mile Post 215, Tracy, dated September 13, 1995. The addendum was prepared on behalf of <br /> Chevron Pipe Line Company (CPL) in response to the Regional Water Quality Control Board's <br /> (RWQCB) Comments on Work Plan for Phase If Remedial Investigations, Mountain View <br /> Townhomes, Tracy, San Joaquin County, dated July 26, 1995 (attached). In general, CPL <br /> concurs with the RWQCB's comments on the work plan as presented in EMCON's addendum. <br /> However, CPL has concerns over the RWQCB's request for following analytical methods: <br /> • Analysis of total recoverable petroleum hydrocarbons (TRPH) using EPA Method 418.1. <br /> • Analysis for total and soluble metals. - <br /> It is CPL's position that these analysis are unnecessary to complete the characterization of this <br /> site and should be omitted from the analytical protocol. The technical reasons for the removal of <br /> these analyses are outlined below. <br /> Method 418.1 <br /> As discussed in previous meetings with the RWQCB, EPA Method 418.1 should be omitted <br /> from the sampling protocol because it is a non analyte-specific analytical technique that will not <br /> provide any additional information beyond the proposed EPA Method 8015 modified using a <br /> crude oil standard. Method 8015 will provide the required quantitative data along with semi- <br /> quantitative information on the type of constituents present. Additionally, soil and groundwater <br /> samples analyzed using EPA Method 8015 will be treated with silica gel (according to laboratory <br /> protocols) in order to remove any positive interferences from non-petroleum organic sources. <br />