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October 30,2009 Mr. Paul Anderson GEM Mobile Treatment Services, Inc. 1196 E.Willow St. Signal Hill,CA 90755 Subject: Secondary Containment for BP Stockton Terminal 2700 West Washington St.,Stockton,CA 95203 Dear Mr. Anderson: I have reviewed the design of the secondary containment for the treatment system that GEM Mobile Treatment Services, Inc. (GEM) proposes to use at the BP Stockton Terminal (the Site) located at 2700 West Washington St., Stockton, California. The treatment system consists of an oil-water separator and activated carbon system. This system is a Transportable Treatment Unit ("TTU") and will be operated at the Site under the State of California Environmental Protection Agency, Department of Toxic Substances Control ("DTSC") Permit-by-Rule ("PBR"). In summary, the container treatment has been designed as follows: • The base consists of a continuous high-density polyethylene liner that is placed on a flat and level surface free of any angular or sharp objects. Similarly, equipment, materials and personnel surfaces that contact the liner are free of angular or sharp objects and equipment is sufficiently anchored or braced to prevent abrasion. The base is free of cracks and gaps and is sufficiently impervious to contain leaks, spills or precipitation. • The containment system is designed to allow liquid drainage and removal of liquids resulting from leaks, spills or precipitation. • The secondary containment has sufficient capacity to contain precipitation from at least a 24- hour, 4hour, 25-year storm plus the volume of the largest container. • Run-on into the secondary containment has been prevented by extending the base liner up and over the berm. The berm is free of any angular or sharp objects and the liner has excess material that will allow filling within the berm area without creating excess tension on the liner. I Wage BP Stockton Terminal October 2009