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AEGIEIVI=[� SEP 0 9 2015 As seen in photos 1 through 3 (Attachment A), the tanks are on the water side of the IES t�NTAL behind the fence structure as show. The pre-deployed boom with a 14 inch skirt would full}tCo+�J54@ACA,T spill from the tanks and enable the use of the oil water separator pad to be quickly deployed from the docks consistent with the terms of the Oil Spill Containment and Response Plan which Bull Frog Landing has in place. This pre-deployed boom is designed to meet the basic intent of the County's secondary containment requirements of ensuring that any spill is held to the smallest possible area of impact and that it be fully accessible to bring in any required cleanup materials. As you can see from the photos 1 through 3 (Attachment A), the containment is the boom but its effectiveness is enhanced by the fact that the area within the containment is kept free of water hyacinth (Eichhornia crassipes) or similar aquatic weeds. This provides two additional advantages: 1) it helps to ensure that an undetected leak will show up (usually as a light sheen), and 2) keeping the area free of weeds combined with the limited area, means that the ability to deploy absorbent pads or other clean up techniques is easily able to be implemented from the surrounding docks and shoreline, which provides a fast and effective response. While I was at the site, I reviewed the marina's Oil Spill Response Plan and procedures and inspected the response material present on-site for deployment should it ever be needed. Both are excellent, fully ready for deployment if needed and sufficient to fully address even the worst case spill (defined as the loss of the entire volume of the largest tank(1000 gal).The spill plan contains all of the key notice provisions and has the updated numbers listed for the first responders to be contacted immediately along with the number of all of the agencies which must be reported to in the event a spill happens. The material (primarily absorbent pads designed to attract petroleum and not water) to facilitate an immediate initial cleanup is readily at hand and the operator is fully trained in the use and deployment of the material so that he can act even prior to any first responders arriving on scene. The fact that the operator lives on- site and must unlock the tank prior to initiating fuelling of vessels is an added precaution from an operational perspective. The containment area itself more than meets the size requirements of the County to be able to fully contain even the largest spill from the largest tank (1000 gal) even if it were to occur when the tank was just filled. This containment capacity of the area enclosed by the pre-deployed boom is greater than the County required capacity which is the size of the largest tank plus an allowance for rain water from a reasonable size storm simultaneously. Certain other facts present also lead me to believe, based on my experience, that the operations of the facility are designed to help both prevent and/or rapidly clean up any spill which might occur. 1) The tanks are relatively-speaking small. There are 3 1000 gallon tanks and 2 five hundred gallon tanks. 2) The capacity of the secondary containment area is normally the capacity of the largest tank plus sufficient freeboard to ensure that there is also capacity for a significant storm event(25 yrs). This is met here. 3) While a normal secondary containment area is designed to prevent the spill from reaching waters due to the location of the tanks that is not feasible here; however, the boom and curtain will result in containment and rapid clean up of any spill. Only a complete re-location or tank replacement with double sided tanks would change things. Given the levee that the tanks are sited along, placing the tanks outside of the levee is not realistically feasible given the limited parking and the likelihood that moving the tanks into the parking lot would increase the chances of them being run into which is even more dangerous and could still result in a spill, fire or other impacts. Further as noted in the letter from Vic Solari (Attachment B), -2-