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t w Chevron to conduct additional groundwater monitoring and to continue subsurface investigation and cleanup activities at its former site.' In response to the Regional Board directive, Chevron submitted an analysis by its consultant stating that the evidence showed only one plume migrating from the Opal Cliffs site that had completely enveloped the former Chevron site. On that basis, Chevron asked for reconsideration of the Regional Board's determination of responsibility for the investigation and cleanup. Chevron asked that, at a minimum, the Regional Board find that any Chevron contribution to the contamination was part of a commingled plume for which cleanup responsibility would be shared between Opal Cliffs and Chevron. On November 9, 2000, the Executive Officer issued another letter order under section 13267, reiterating staff's conclusion that the evidence showed two separate sources of contamination. Nonetheless,the letter acknowledged some elements of a commingled plume and recommended that Chevron pursue a commingled plume agreement with Opal Cliffs in order to fund and implement the cleanup. The letter required submission of a status report on the commingled plume agreement and other aspects of the cleanup, no later than December 1, 2000. On December 7, 2000, Chevron timely filed a petition to the State Board, seeking review of the Regional Board's determination. Chevron asked that action on the petition be held in abeyance pending negotiations with the Regional Board and other parties. On June 20, 2003, Chevron submitted a supplement to the earlier petition and asked that the State Board initiate review of the matter. II. CONTENTIONS AND FINDINGS Contention: Chevron contends that evidence collected to date shows a single plume of petroleum hydrocarbon contamination spreading from the Opal Cliffs site onto the former Chevron site. On this basis, Chevron argues that it should not be held responsible for the continuing investigation and cleanup at the site of its former service station. Finding: This Board agrees. There is not substantial evidence in the administrative record to support the Regional Board's finding that high concentrations of ' Roger W. Briggs,Executive Officer,to Mark R. Lafferty,Project Manager,Chevron Products Company, September 12,2000. 3.