SITE INFORMATION AND CORRESPONDENCE

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Mr. Sergio Morscalchi Atlantic Richfield Company 2 17 March 2009 The Annual Report attributes the concentration increases observed in the wells to the fire suppression foam release. After reading the report of the spill, Regional Water Board staff (1) faxed a records-search request to the San Joaquin County Office of Emergency Services (OES) to verify that the spill was appropriately reported, (2) spoke with Stantec staff who stated that they planned to perform a 10-volume well over-purge to address any fire suppression foam discharge that may have entered through the surface completion of the wells, and (3) made an appointment with site manager, Mike Peterson, to conduct a site visit. I conducted the site visit on 24 February 2009. 1 was accompanied by BP Environmental Coordinator Debra Portello, Environmental Business Manager Sergio Morescalchi, and site workers Dennis Leiker and Frank Yiamkis. We conducted a site walk during which I was shown the general extent of the foam discharge in the loading rack and secondary containment areas. I observed no residual signs of the foam discharge either on the paved surface of the loading rack area, or in the unpaved AGT secondary containment area during the site walk. We also held discussions before and after the site walk. During the meetings, Debra stated that the spill had not been reported to the OES and, contrary to Appendix O, disputed accounts that any of the discharge left the site. Sergio said that the discharge was not disclosed during a 7 January 2009 meeting with Regional Water Board staff because BP was still evaluating the spill. Debra stated that she understood that the 22 February 2002 storm water permit for the facility, No. 97-03-DWQ, allowed the discharge of the foam as one of the authorized non-storm water discharges in Section D Special Conditions. However, neither a review of the permit kept on site, nor a copy emailed to me on 26 February 2009 shows this to be the case. BP presented a laboratory report detailing the results of laboratory analytical testing of the foam/rinse-water mixture and contents of AGT No. 7. The sample was collected from a 20,000-gallon baker tank to which the mixture had been transferred for transportation and disposal at a facility in Compton, California. The laboratory report showed that the mixture contained ethanol at 1,600,000 pg/L. There were also elevated levels of TPHg, TPHd, benzene, toluene, ethylbenzene and xylenes (collectively BTEX), jet fuel, crude oil and TBA. Methylene blue active substances (MEAS), an indication of the presence of fire suppression foam, was detected at 14,000 Ng/L. MBAS has a secondary maximum contaminant limit (MCL) of 500 pg/L. BP staff emphasized that there was no discharge of petroleum product during the incident and that the high levels of petroleum hydrocarbons observed in the laboratory report were the result of an accumulation of minor spills that occurr at the loading rack during normal loading operations. During my visit, I observed that the pavement at the loading rack was dry with only minor staining. Our comments are presented below. 1. We request that BP provide a map identifying Tank 7 and the areas that were submerged by the November 2008 fire suppression foam and foam/water mixture releases.