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Wendy Cohen -3- 17 March 1992 <br />management unit and subject to the requirements of Chapter 15. Chapter 15 requires <br />that the depth to ground water be maintained at no less than five feet below the <br />ground surface and that the containment area be lined. <br />Because this is not a typical waste management unit for the permanent storage of <br />hazardous wastes, an engineered alternative to the requirements of Chapter 15 may be <br />appropriate. One such alternative could be to line the containment area and have a <br />detailed plan for immediate cleanup of any releases of petroleum products. Such a <br />plan should state the method of the spill cleanup and provide a minimum timeline for <br />any cleanup. Other alternatives may be to lower the water table by pumping or to <br />fill in the containment area to increase the distance between the ground surface and <br />the water table. <br />CONCLUSIONS AND RECOMMENDATIONS <br />Except for the containment area berms, the facility appears to be fairly well <br />maintained and properly operated. I recommend that the berms which have not been <br />gunnited be regraded and coated with gunnite or some other impervious material which <br />will not only contain any spills, but which will also resist erosion. <br />Chevron should be required to submit a Report of Waste Discharge and NPDES permit <br />application for the discharge of water to and from the lower containment area. The <br />application must contain a full chemical characterization of all waste streams and <br />their expected volumes of discharge. <br />Chevron also should be required to address the threat to ground water posed by the <br />shallow ground water and the possible temporary storage of any petroleum product <br />released to either containment area. <br />