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SECOR www.secor.com <br /> INTERNATIONAL 3017 Kilgore Road Suite 100 <br /> INCORPORATED Rancho Cordova,CA 95670 <br /> S E C O f? 916-861-0400 TEL <br /> 916-861-0430 FAX <br /> RECEVVC1=,DD <br /> May 16, 2008 <br /> MAY 1 9 2008 <br /> ENVIRONMENJ-HEALTH <br /> Mr. Brian Taylor PERMIT/SERVICES <br /> Regional Water Quality Control Board—Central Valley Region <br /> 11020 Sun Center Drive, Suite 200 <br /> Rancho Cordova, California 95670-6114 <br /> Re: Reconsideration of Baseline Levels <br /> BP Stockton Terminal #40T <br /> 2700 West Washington Street <br /> Stockton, California <br /> SECOR Project No.: 77BP.0040T.02.0236 <br /> Dear Mr. Taylor: <br /> On behalf of Atlantic Richfield Company, a BP affiliated company, SECOR International <br /> Incorporated (SECOR) has prepared this Reconsideration of Baseline Levels for an Enhanced <br /> Bioremediation Pilot Study approved in the recently published Order No. R5-2008-0064(the"Order") <br /> at the BP Terminal (the "Site") located at 2700 West Washington Street, Stockton, California. As <br /> part of the Order, an implementation schedule was requested. Until revised Baseline Levels are <br /> received a schedule for implementation cannot be developed. <br /> Upon review of the Order, it was noted that implementation of a contingency plan via active <br /> groundwater extraction would be required (Point 15, page 4 of Order) if concentrations were <br /> confirmed above 20%of Baseline Levels(Section C, page 8 of Order)in AR/MW-1A. As discussed <br /> during our phone conversation Wednesday, May 7, 2008,this pilot study's contingency plan would <br /> require active groundwater extraction of groundwaterwith nutrient concentrations that are two orders <br /> of magnitude below water quality objectives. <br /> SECOR respectfully requests Order No. R5-2008-0064 be revised to set baseline levels in AR/MW- <br /> 1A equal to water quality objectives for the identified constituents listed in Section C, page 8 of <br /> Order and that the contingency plan be implemented if concentrations exceed these levels in two <br /> consecutive measurements at this location (AR/MW-1 A). <br /> If you have any questions, please contact us at 916-861-0400. <br /> Prepared by: <br /> Brian Westhoff <br /> Senior Geologist <br /> Reconsideration of Baseline Levels.doc <br />