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STATE OF..CALIFORNIA PETE WILSON, Governor <br /> CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD— <br /> CENTRAL VALLEY REGION r <br /> 3443 ROUTIER ROAD, SUITE A <br /> SACRAMENTO, CA 95827-3098 <br /> PHONE: (916) 361-5600 26 June 1992 <br /> FAX: (916) 361-5686 <br /> RECEIVE <br /> Ms. Lynn Rogozinski JUN 3 0 1992 <br /> BP Oil Compan9 <br /> 4850 East 49t Street ENVIRONMENTAL HEALTH <br /> Cleveland, Ohio 44125-1079 PERM IT/SERVICES <br /> REQUEST FOR A GROUND WATER MONITORING PROGRAM FOR BP OIL COMPANY, STOCKTON FACILITY, <br /> SAN JOAQUIN COUNTY 3So15 JAY �tZ <br /> We have reviewed your 8 May 1992 response to our 6 April 1992 inspection report for <br /> the subject facility. Your responses to our concerns are adequate, except your <br /> response on the ground water monitoring system. Our comments are discussed below. <br /> The monitoring program at the facility consists of product reconciliation and tank <br /> water bottom monitoring. Our experience with these monitoring systems shows they <br /> are unreliable to determine impacts to ground water. Product reconciliation is <br /> undependable because product volume changes constantly with changes in temperature <br /> and pressure. Tank water bottoms also are not trustworthy because the volume of <br /> both product and water are affected by changes in temperature and pressure. Also <br /> some product gets dissolved in the water which could get discharged to the environ- <br /> ment through leaks. Thus, gaging may show loss of water only, when in fact the <br /> discharged water contained dissolved constituents. <br /> You also state that BP's target for product loss is +/-0.02%. What percentage loss <br /> is actually being achieved by BP? Using the largest tank volume of 1. 176 million <br /> gallons, the 0.02% product loss represents about 235 gallons. This loss is <br /> substantial in terms of discharge to ground water. Therefore, we deem that your <br /> monitoring program is inadequate to protect the ground water beneath your facility <br /> in Stockton. <br /> By 16 July 1992, please submit a work plan and time schedule to install a ground <br /> water monitoring well network. At a minimum, the network shall consist of one <br /> upgradient well and two downgradient wells, but additional wells may be necessary to <br /> monitor ground water beneath all potential sources of contamination onsite. The <br /> work plan shall include at least proposed well locations, justification for those <br /> locations, and well construction and completion details. <br /> If you have any questions, please call me at (916) 361-5650. <br /> L , W 'V <br /> '� X- HILIp . ISORENA <br /> Sanitary Engineering Associate <br /> cc: Mr. Harlin Knoll , San Joaquin Public Health Services, Stockton <br /> Mr. Jeff Withrow, BP Oil Company, Stockton <br />