• Continued fine-tuning the treatment system;
• Started up the treatment system on January 18, 2012.  During startup activities, the carbon vessels were determined to be the source of short system run times and high operating pressures. BP reconfigured carbon vessels to run three lead vessels in parallel (instead of one lead/lag series pair) to mitigate backpressure on the transfer pump downstream of the air stripper sump. This reconfiguration was determined to be successful based upon greater system run times and lower operating pressures across the system;
• On February 9, 2012, the treatment system compressor was discovered to have power loss. Compressor was uninstalled and transported to local mechanic for repairs; 
• Collected monthly treatment system samples;
• Conducted aquifer testing January 25 through February 1, 2012;
• On January 31, 2012, BP submitted QAPP, SAP, and HASP revisions with wet signatures;
• Conducted semi-monthly operation and maintenance (O&M) of LNAPL recovery system installed at DHW-110; 
• Conducted semi-monthly manual LNAPL recovery and related breathing zone monitoring;
• On February 5, 2012, BP responded to a discharge of petroleum-contaminated groundwater from the treatment system. The system was shut down, the site was secured, and recovery of discharged groundwater was conducted. BP is conducting a root-cause analysis (RCA) investigation and will provide the results to EPA under separate cover in an incident summary report which will be submitted to EPA on February 17, 2012; 
• On February 6, 2012 BP notified EPA of a discharge of petroleum-contaminated water from the treatment system;
• On February 8, 2012, BP submitted a post-incident monitoring plan for the treatment system discharge, based upon February 7, 2012 discussions with EPA's On-Scene Coordinator (OSC). BP will continue to conduct post-incident sampling, including soil, groundwater, and surface water, as conditionally approved by EPA in the letter dated February 9, 2012. Un-validated analytical results will be shared with the OSC upon receipt; 
• On February 10, 2012, BP requested an extension of the deadline for continuous system operation from February 12 to a later date, based upon the conclusions of a root-cause analysis of the treatment system failure; 
• On February 10, 2012, EPA's Office of Regional Counsel, in consultation with the OSC, confirmed that the BP's deadline extension request was acceptable. BP will provide EPA a revised schedule and start-up deadline by February 17, 2012;
• On February 12, 2012, Stantec submitted Investigation Work Plan per paragraph V.31 of the Order; and
• On February 14, 2012, manual LNAPL recovery was conducted on DHW-110. Three gallons of LNAPL were recovered.

• Continue to provide oversight and documentation support to OSC;

• Continue post-incident monitoring and analytical results reporting to OSC;

• Conduct Little Eagle Creek monthly surface water sampling;

• Continue to optimize pump and treat system in anticipation of re-start; and 

• Repair of damaged carbon vessels.

2.2.1.2 Next Steps
BP will continue collecting surface water and groundwater samples until the treatment system is operational again.

2.2.2 Issues
See Response Actions to Date, Section 2.1.2.