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ANALYTICAL ENVIRONMENTAL SERVICES RECEIVEL—) May 28, 2015 SEP 0 9 2015 Da-Les Auto Body Inc. ENVIRONMENTAL. Attn: Dave Ressa— President 14C61Tu nCOADTRAC^IT 1085 Happy Valley Avenue San Jose, CA 95129 Subject: Report on Bull Frog Landing Pete Bontadelli, Director of Biology and Permitting at Analytical Environmental Services (AES) and former Director of California Department of Fish and Wildlife(CDFW) and first Administrator of the Office of Spill Prevention and Response (OSPR) for the State, visited the site on May 14, 2015. The visit was to observe firsthand the conditions at the Marina in light of the ongoing issues raised by San Joaquin County regarding the lack of secondary containment for the Marina's existing gas storage tanks. The County requirements basically require that single sided petroleum tanks have a secondary containment in order to contain any possible leaks or spills. In general this containment is intended to prevent any possible spill from getting into the Waters of the State or US. These County standards take into consideration special circumstances where the use of traditional secondary containment is "infeasible". As photos 1 through 3 (Attachment A) show the location of the tanks is basically immediately adjacent to or over the water and given the levees and need accommodate deliveries it is infeasible to move them. As the attached letter(Attachment B)from Vic Solari, who advised the County on fire related issues, which discussed the current fire code. The owner also expressed some concerns that any attempt to move or replace tanks if not done very carefully could create substantial safety risks as well since such tanks are a potential bomb if not handled correctly, From my time as the first Administrator of OSPR during which I was responsible for overseeing the initial drafting and finally approval of most of the regulations which govern oil facilities of all sizes throughout the State, I know that small marinas, such as Bull Frog Landing, are exempt from many of the more stringent requirements of the State Oil Spill Act. This limit and partial exemption is also present in the Federal Oil Spill Act regulations; again I was part of the Negotiated Regulatory Committee which advised the Coast Guard on the drafting of those regulations as well. In order to qualify for these exemptions and lessening of requirements, a set of circumstances must be present. In addition to size (which this facility clearly meets), the petroleum product stored and handled must be only gasoline and other non heavy oils. This requirement is based on the fact that the primary cleanup of any spill of such light oil material is primarily containment and limited use of absorbents which pick up the petroleum product and not water combined with evaporation over time. The material stored at this facility (gasoline only) fits this description. Following initial containment and removal with the oil water separator absorbent pads, sunlight, and evaporation is the primary tool when it comes to addressing this type of spill. While there are some impacts, they are limited if fully contained. 1801 7TH STREET, SUITE 100 • SACRAMENTO, CA 95811 • TEL 916.447.3479 FAX 916.447.1665 www.analyticalcorp.com