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California Regional Water Quality Control Board Central Valley Region 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 28 March 2001 Mr. Scott Hooton Mr. Larry Silva Mr. Kyle Mullins BP Oil Company Tosco Refining Company ST Services 295 SW 41" 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 MONITORING AND REPOTING PROGRAM NO. 5-01-814, FORMER BP TERMINAL #10013, STOCKTON, SAN JOAQUIN COUNTY We have reviewed the 26 January 2001 letter from Scott Hooton of BP Oil for the former BP Oil Bulk Terminal No. 10013, 3505 Navy Drive in Stockton. The letter contains comments on the draft monitoring and reporting program (MRP), which we sent on 3 January 2001. BP Oil proposes that EPA Method 8020 be used instead of EPA Method 8260 for fuel oxygenate and total petroleum hydrocarbon (TPH) as gasoline analyses, that DIPE, ETBE, TAME, TBA, ethanol, and methanol be removed from the monitoring list, and that required detection limits be raised by one order of magnitude. Furthermore, BP Oil proposes that benzene, ethylbenzene, toluene, xylenes (collectively BTEX), TPH as gasoline and TPH as diesel be removed from the monitoring list based on the concentrations generally declining by natural attenuation. We concur that EPA Method 8020 may be used for fuel oxygenates and TPH as gasoline since these constituents have been confirmed by EPA Methods 8260 and 8015M. As stated in the footnote of the monitoring requirements table, any wells that have been sampled for fuel oxygenates by EPA Method 8260 and have shown no detectable concentrations using the required reporting limit, do not need to be sampled again in that monitoring well for that analyte. The fuel oxygenate requirements will remain in the MRP for future monitoring wells. The required method reporting limits will remain as listed because these limits are achievable by most laboratories. BTEX, TPH as gasoline and TPH as diesel will continue to be required analyses to confirm plume migration or stability. Enclosed is the final MRP No. 5-01-814, which should be implemented at the site during the second quarter 2001. California Environmental Protection Agency gip• 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.swrcb.ca.gov/rwgcb5