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GENESIS ENGINEERING&REDEVELOPMENT Howard F. Hold, P.G. February 6, 2012 Page 3 Response The farmed area immediately east of the Site is now below sea level, as are the native soils underlying the drill mud at the Site. There are believed to be at least 5 feet between the land surface (at elevation-5 feet) and the water table (at elevation-10 feet in the monitoring wells along the eastern side of the Site)at the proposed background sampling location. Farming does disturb the upper portions of the soil, and may make the field less than ideal as a background sample area. To diminish the effect of that issue, we propose to sample the soil beneath the tilled layer and beneath common rooting depths of the plants farmed. The minimum sampling depth at each location will be 4 feet. Soil logging by the field geologist will confirm that there are no longer any roots, or evidence that the soil has been disturbed at this depth,prior to sample collection. Furthermore, it is noted that(1)the native soils beneath the Site contain a layer of organic material from the former vegetated ground surface, indicating that the Site itself once hosted either native vegetation and/or tilled crops, and (2)background soil sample analysis will be primarily for inorganic constituents, and the presence of roots and natural organic matter will have no impact on those analyses. RWQCB Comment: Staff has also reviewed the Sampling and Analysis Plan(SAP) included as Appendix A of the work plan. Staff compared the Discharger's SAP to the enclosure, titled"Required Contents for a Sample Collection and laboratory Analysis Plan"to evaluate compliance. The enclosure lists the information that is included in a complete SAP. While the majority of the information was present in the existing SAP, staff identified the following items that appear to be missing or need greater detail added. A revised SAP should also be included in the 7 February 2012 revision to the work plan. Response: The enclosed SAP has been revised to include the items listed in the RWQCB's December 29, 2011 letter, as follows. • The original SAP contained a table(Table A-2)with analytes and analytical methods for each sample location(all soil samples will be analyzed for the same analytes). GE&R has added Table A-2, with a list of boring designations and sample identification information.