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Memorandum CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD • CENTRAL VALLEY REGION 3201 S Street Sacramento, California 95816 Phone: 445-0270 TO: Antonia Vorster FROM: Daniel Ward Senior Engineer Project Engineer DATE: 2 May 1986 SIGNATURE: iaikt -17 C(JCl.k-j SUBJECT: SOUTHERN PACIFIC PROPOSAL FOR SOIL AND GROUND WATER INVESTIGATIONS AND CLEANUP My comments on the proposal dated 31 March 1986 submitted by the MARK group for Southern Pacific Pipeline (SP) are as follows: In general this is a well written and well documented submittal. The detection limits for the volatile aromatic chemicals in soil and water analyses submittal are unacceptable. Since OHS action levels and probable cleanup levels are in the range of ugh, detection limits of future analyses should be those specified by EPA Method 602. All booms intended to prevent introduction of hydrocarbons into surface waters should remain in place until the soil cleanup is complete. Drawing 7 shows that soil samples will be taken in a line parallel to, but 20 to 30 feet south of the "new pipe section", which is at the northern boundary of the site next to Trapper Slough. During the excavation of the trench for the placement of the new pipe section", I saw free petroleum product floating on the water in this trench. Unless sampling is done to prove otherwise, we will assume that there is petroleum saturated soil from the proposed sampling locations to the slough which must be addressed in the cleanup plan. SP proposes to air develop the wells. The wells will be so shallow that mechanical development of the wells is more desirable and feasible. SP proposes two-inch wells. Four-inch wells are much easier to develop and sample from, and they are recommended. Prior to sampling, wells must be purged for sampling until pH, EC and temperature are stabilized. Samples shoed 1-,e collected with a bailer. SP proposes that a maximum of three additional wells will be constructed. This is an arbitrary number and additional wells may be required. SP has proposed to use PVC pipe for their wells. They need to prove that the high levels of volatile aromatics will not degrade the PVC. If this cannot be established, another casing material must be used.