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Mr. Sergio Morscalchi - 3- 17 March 2009 <br /> Atlantic Richfield Company ' • <br /> 2. During the 24 February 2009 meeting, BP stated that the spill had not been reported <br /> to the OES. We believe that BP should do so in order to determine whether the <br /> response to the spill complied with applicable regulatory protocol. <br /> 3. We are concerned that the elevated levels of petroleum hydrocarbons observed in <br /> monitoring wells located in areas that were covered by the foam/water mixture <br /> indicate that the surface completions of these wells are not watertight. As discussed <br /> in the 24 February meeting, we request that BP add MBAS to the quarterly <br /> monitoring program for all AR/MW wells for all four quarters of the 2009 monitoring <br /> year. The monitoring results will be evaluated to assist in determining whether the <br /> route of entry of TBA and other constituents of the fire suppression foam was <br /> through the well seals. <br /> 4. We reviewed the Field Data Sheets in Appendix D to assess how much purging was <br /> done to the AGT secondary containment area wells prior to sampling. It appears that <br /> some data on these sheets, including the purge volumes and/or the well names, <br /> have been erased. These data, however, are clearly recorded for wells outside the <br /> AGT secondary containment area. BP needs to explain why the some of the Field <br /> Data Sheets were altered and to provide the missing data. <br /> 5. We are concerned that BP attributes the concentration increases seen in the 4th <br /> quarter monitoring to an accumulation of minor spills that occur regularly in the <br /> loading rack area. If such spills are a regular occurrence and can accumulate to the <br /> point of causing concentration increases in monitoring wells, BP needs to review and <br /> revise its spill control and cleanup procedures for this area. <br /> By 1 May 2009, please provide responses to our comments above. If you have any <br /> questions regarding this letter, you may contact me at (916) 464-4811 or by email at <br /> betaylor@waterboards.ca.gov. <br /> BR �AYLO , P.G. <br /> Engineering ologist <br /> cc: Ms. Nova Clemenza, Regional Water Quality Control Board, Rancho Cordova <br /> Ms. Margaret Lagorio, San Joaquin County Environmental Health Department, <br /> Stockton <br /> Mr. Jeffrey Wingfield, Port of Stockton <br /> Mr. Mark Chandler, Time Oil Company, Seattle, WA <br /> Mr. Jeff Baker, Tesoro Companies, Inc., Auburn, WA <br /> Mr. Gary Haeck, Stantec Consulting Corporation., Rancho Cordova <br /> Mr. Mark O'Brien, Environmental Risk Services Corporation, Alamo <br /> Mr. Jeremy Hughes, LFR Inc., Granite Bay <br /> Ms. Vicki Goodenow, NuStar Energy, San Antonio, TX <br /> Ms. Helen Dong, Office of Emergency Services, Stockton <br />