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Wendy Cohen -2- 17 March 1992 section of the lower containment area to the next section. Each drain has a valve to regulate flow of water from one section to another. The berms surrounding the western and southern sides of the upper containment area appear to have some erosion damage. I noted several puddles in both containment areas. The puddles may have been from recent rainfall or the high water table (the water table varies from about two feet to ten feet below ground surface). There was no evidence of an oil sheen or discoloration in any of the puddles. In October 1981 Chevron submitted an application for an NPDES permit to discharge tankyard and truck wash oil/water separator effluent and stormwater runoff to the San Joaquin River. The application was incomplete because Chevron did not perform sufficient sampling and analysis of the proposed discharge. A 6 February 1984 letter from Chevron asked Board staff if additional information was required to issue the NPDES permit. A 4 December 1987 letter from Board staff required Chevron to submit a Report of Waste Discharge (RWD) by 10 January 1988, including a full waste stream characterization with chemical analyses of oil/water separator effluent to the on-site evaporation pond (i.e., the lower containment area). No complete RWD was submitted. A complete RWD and NPDES permit application still are needed to permit these discharges. I reviewed the SPCC Plan kept on site and made some recommendations for the revised plan which is being written and should be completed within the next month. The attached SPCC Plan checklist (Table 2) summarizes my review of the plan. My recommendations include: 1) adding emergency phone numbers to the plan (Ms. Cargill did this at the time of the inspection); 2) adding a brief discussion of the ground water monitoring system, such as the number of monitoring wells, a map of their locations, and the frequency of monitoring; 3) having the maintenance inspection reports initialled or signed by the inspector and included in the plan; and 4) adding a record of employee training and a discussion of applicable state laws to the plan. Some changes at the facility which will be noted in the revised SPCC Plan are the addition of two new storage tanks, the discontinued use of one of the three oil/water separators, the addition of a carbon treatment system for effluent from the two remaining oil/water separators, and the conversion of one storage tank from leaded to unleaded plus gasoline. To protect surface waters the APSA requires that the secondary containment be large enough to contain the contents of the largest tank plus stormwater runoff. Chevron meets this requirement including both the upper and lower containment areas. To protect ground water, Chapter 15 of Title 23 of the California Code of Regulations requires that no waste management unit be within five of the highest anticipated water table. Although the containment areas are not typical waste management units, their purpose is to temporarily store hazardous wastes in emergency situa- tions. Presumably any releases of petroleum -contaminated water to the containment area would be cleaned up as soon as possible. However, no matter how quickly a release is cleaned up, it is very probable that any petroleum -contaminated water discharged to either the upper or lower containment area would reach the shallow ground water. The containment area, therefore, should be considered a waste