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California Regional Water Quality Control Board Central Valley Region M ' Robert Schneider,Chair Winston H.Hickox Gray Davis Secretaryfor Sacramento Main Office Governor Environmental Internet Address: http://www.swrcb.ca.gov/rwgcb5 Protection 3443 Routier Road,Suite A,Sacramento,California 95827-3003 Phone(916)255-3000•FAX(916)255-3015 � I 31 May 2001 Mr. Scott Hooton Mr. Larry Silva Mr. Kyle Mullins BP Oil Company Tosco Refining Company ST Services 295 SW 41St Street P.O. Box 2628 17304 Preston Road Building 13, Suite N 9645 Sante Fe Springs Road Suite 1000 Renton, WA 98055-4931 Sante Fe Springs, CA 90670 Dallas, TX 75252 REVIEW OF FIRST QUARTER GROUNDWATER MONITORING REPORT, FORMER BP TERMINAL #10013, STOCKTON, SAN JOAQUIN COUNTY We have reviewed the 11 May 2001 First Quarter 2001 Groundwater Monitoring(Report) submitted by BP Oil Company for the former BP Oil Bulk Terminal No. 10013, 3505 Navy Drive in Stockton. The Report includes a cover letter that states the rising methyl tertiary butyl ether(MTBE) concentrations in monitoring wells MW-2 and MW-8 correspond to Tosco Refining Company's (Tosco) operation of the facility, and contains historic data tables, field data sheets, a groundwater contour map, a concentration map, and laboratory data sheets (including chain of custody forms). However,the Report does not include the following information: • A brief discussion/summary of the first quarter data; • A brief discussion/comparison of first quarter data with historical data; • A brief discussion of groundwater trends, fluctuations, and gradients for the first quarter; and • A brief comparison of first quarter groundwater trends compared to historical results. In addition to the above information, we have the following comments on the Report: 1. The Report cover letter states that the highest MTBE concentrations are in monitoring wells closest to the vapor recovery line. ST Services closed the vapor recovery line after it purchased the property from Tosco in October 1998. The Report should explain why MTBE concentrations are increasing near the vapor recovery line,which has been inactive for more than two years. 2. The vapor recovery line should be shown on figures. These general elements of the quarterly monitoring reports are required by and outlined in Monitoring and Reporting Program(MRP)No. 5-01-814. They are needed to evaluate trends in the contaminant concentrations,whether the contaminant plumes are fully defined, and the adequacy of the monitoring network. All quarterly groundwater monitoring reports must include all the information required by the California Environmental Protection Agency 05 Recycled Paper The energy challenge facing California is real. Every Californian needs to take immediate action to reduce energy consumption. For a list of simple ways you can reduce demand and cut your energy costs,see our Web-site at http://www.swreb.ca.gov/rwgcb5