Laserfiche WebLink
a BP OIL BP Oil Company <br /> Environmental Resources Management <br /> Building 13.Suite N <br /> 295 SW 41st Street <br /> Renton,Washington 98055-4931 <br /> (206)251-0667 <br /> Fax No:(206)251.0736 <br /> December 10, 1996 <br /> t[� <br /> California Regional Water Quality Control Board - Central Valley Region <br /> Attention Ms. Elizabeth Thayer- Associate Engineer <br /> 3443 Routier Road, Suite A -- -r` <br /> Sacramento, CA 95827-3098 •t: <br /> RE: NPDES Permit 92-023 <br /> Former BP Oil Site No. 11194 ate, <br /> 2375 Tracy Boulevard <br /> Tracy, CA <br /> Dear Ms. Thayer: <br /> This letter responds to your letter to Ms. Angela Abegg of 5 December 1996 regarding <br /> the above-captioned NPDES permit. BP's request to cancel the permit was prompted by <br /> an annual fee for the Bay Protection and Toxic Cleanup Program for the period of 1/1/97 <br /> to 12131/97, invoiced no. 9609150, dated 1117196. The NPDES permit expiration date is <br /> 1/1/97. Ms. Abegg wrote the letter to confirm that BP did not need or desire the ability <br /> to discharge water allowed by the permit. Based on this notice, BP assumed that we <br /> would not be billed for an annual discharge ($2,000 per year) and the Bay Protection and <br /> Toxic Cleanup Program ($4,000 per year) because no further discharges are planned. <br /> Your letter declined BP's 18 November 1996 request to cancel and rescind the NPDES <br /> permit, based on the following rationale: <br /> 3 <br /> "Our file contains no notice from San Joaquin County staff that the treatment and discharge systems <br /> are no longer needed Neither does our file contain an analysis of the treatment and discharge <br /> systems, indicating that they have become inefficient, obsolete, or unnecessary. Once we have <br /> received notification from County staff and reviewed a report containing an analysis of the treatment <br /> and discharge systems, we can consider a request to rescind(the NPDES permit}" <br /> This rationale ignores the requirements of the permit, specifically Provision No. 6 of <br /> NPDES Permit 92-023. Provision 6 reads as follows: <br /> "This Order expires on l January 1997 and the Discharger must file a report of Waste Discharge in <br /> accordance with Title 13, CCR, not later than 180 days in advance of such date in application jor <br /> renewal of waste discharge requirements if it wishes to continue the it wishes to continue the discharge. <br /> BP did not file this report because it had no plan,1intention, wish or desire for further <br /> discharges. <br />