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Stantec Consulting Inc. 57 Lafayette Circle 2nd Floor Lafayette CA 94549 Tel:(925)299-9300 Fax:(925)299-9302 Stantec mo ECS November 10, 2008 NOV 1 3 2008 Mr. Brian Taylor ENVIRONMENT HEALTH Regional Water Quality Control Board — Central Valley Region PERMIT/SERVICES 11020 Sun Center Drive, Suite 200 Rancho Cordova, California 95670-6114 Reference: Work Plan for Amended Bioremediation Pilot Study Dear Mr. Taylor: On behalf of Atlantic Richfield Company, a BP Affiliated Company, Stantec Consulting Corporation (Stantec) has prepared this Work Plan for Amended Bioremediation Pilot Study at the BP Terminal (site) located at 2700 West Washington Street in Stockton, California. This work plan was prepared in response to several conference calls and meetings with the Regional Water Quality Control Board (RWQCB) regarding the Enhanced Bioremediation Pilot Study proposed by Stantec for treatment of petroleum hydrocarbons in shallow groundwater. The purpose of this amended work plan is to avoid potential problems associated with background concentrations of proposed electron acceptor/nutrient reagents. The following sections provide the details for injection of electron acceptor/nutrient into groundwater to stimulate microbial degradation of petroleum hydrocarbons. SITE DESCRIPTION AND HISTORY The site covers approximately 9.6 acres and is located in San Joaquin County, on the southwest side of the City of Stockton, within an area defined as the Port of Stockton Terminals. The site is located approximately 2,000 feet (ft) east of the San Joaquin River and 2,500 ft south of the Stockton Deep Water Channel. The site is bound to the north by West Washington Street and to the east by Stork Road (Figure 1). The site is essentially flat, with a slightly lower groundwater surface in the containment basin that contains six large aboveground storage tanks. The aboveground storage tanks are located within a containment basin surrounded by a concrete perimeter wall. The tanks within the containment basin are serviced by lateral underground product supply lines that extend south from the Stockton ship channel, across the vacant parcel north of the site beneath Washington Street. Most of the site is covered with either asphalt or concrete; however, within the containment basin the ground is covered with gravel. Aboveground facilities include loading islands, a warehouse and garage, an office building, six aboveground fuel storage tanks, a vapor recovery unit, and four aboveground water storage tanks. A site plan is included in Figure 2. The site is an operating fuel storage and distribution terminal and is located within an industrial area with a long history of operation. The terminal and surrounding properties are zoned M-2 for heavy industrial use. Properties adjacent to the site include three additional fuel storage and distribution terminals (terminal lease area), a cogeneration plant, bulk fertilizer distribution 40T Work Plan for Amended Bioremediation Pilot Study.doc ti