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i Bullfrog Landing Marina Spill Prevention, Control, and Countermeasure (SPCC) Plan PART 3: Discharge Prevention - General SPCC Provisions The following measures are implemented to prevent oil discharges during the handling, use, or transfer of oil products at the facility. Oil-handling employees have received training in the proper implementation of these measures. 3.1 Compliance with Applicable Requirements (40 CFR 112.7(a)(2)) This facility uses active measures for secondary containment of its system to contain oil discharged in certain areas of the facility (i.e., overfills, and the loading/unloading area associated with ASTs). The facility is making an impracticality determination for not implementing a passive secondary containment system for the following reasons: • The storage facility is located on a wooden platform situated on the waterside of a levee roadway. The facility has been in operation in substantially it current condition and function since sometime in the 1960's. • A dike or berm around the storage facility would at times be submerged under normal tidal waters and would be ineffective. • Construction of a wall or containment berm would require construction on the levee embankment and within the river channel. Structural support for a wall or berm would have to be developed by piers or piles drilled into the levee. The existing levee materials would be expected to be unable to provide adequate bearing support. In addition, excavations into the levee and piles are prohibited by the levee Reclamation District No. 2038 and the US Army Corp of Engineers. • Relocation of the storage tanks to the landside of the levee is not an option due to requirements to place the new storage tanks above the flood plain and outside beyond) the levee footprint. This would mean a substantial tower, 20 feet or so in height located several hundred feet away from the facility. Leaks or spills caused by vandalism or accident in the interconnecting piping between the storage tank and the facility would be a much greater concern in this situation. The ability to fill the elevated storage tanks by fuel delivery trucks would become, at least more difficult. Also, the facility owner does not have ownership of this land. • Relocation of the storage tanks off of the wooden platform and piers on the ground would place the tanks very near, if not in, the vehicular travel way, making the potential for vehicular collision greater. • Placement of a secondary containment "tray" under the tanks will require the temporary relocation of the tanks. The temporary removal and relocation, and then the reinstallation of the tanks would be required to be performed by specialized contractors who are appropriately trained and experienced in handling potentially explosive fuel tanks. The cost for these services is considered to be prohibitive. • Recommendation by Mr. Pete Bontedelli, 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 as provided in attached letter (APPENDIX K) -11-