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Shell Oil Company -2- 23 March 1992 Stockton Facility Prior to the inspection, Shell sent us its Spill Prevention Control and Countermea- sure (SPCC) Plan. My comments on the plan are provided in Table 2 and further ex- plained below. The comments are numbered according to the checklist numbering. 5. Appropriate emergency numbers are not included in the plan. 8. Attachment 1 in the plan provides a record of spills to the Stockton Deep Water Channel. The record shows there have been no spills to the channel within the last 12 months. A record of spills which may not have reached the channel also should be provided. 26. Applicable laws and regulations are not cited in the plan. For example, Section 25270.7(d) of the APSA requires the facility to report all positive findings from the detection systems to the Regional Board within 72 hours after learning of the finding. Also, Section 25270.8 requires the facility to immediately notify the city, county, and the Office of Emergency Services of a spill of one barrel (42 gallons) or more. 29. Monitoring of the discharge of storm water from the containment area consists of visual observation, which may not be protective of surface or ground water quality. 33. The plan states that the containment area was designed in accordance with the National Fire Code (NFC) specifications, but does not state what the capacity is. Section 25270.5(d)(3) of the APSA requires containment for the contents of the largest tank plus sufficient space for rainfall in order to protect waters of the state. Thus, the plan must discuss if the NFC specs provide adequate capacity and ground water quality protection. If not, then the plan must specify how these will be achieved. 34. The ground water monitoring system is discussed in numerous reports, but not in the SPCC plan. Soil and ground water remediation is proceeding. 35. A contingency plan exists but is not included in the SPCC plan and was not submitted to the Board. 36. The plan does not contain a specific written commitment to control spills. 37. The site plan must include the direction of sheet flow in areas outside the containment area and the locations of the discharge point, the valve which controls the discharge from the containment area, the storm water disposal area, surface water drainages, and surface water bodies using a convenient scale. 50. The plan does not contain inspections and other records. 52. The plan is reviewed with all employees annually. Other types of training are provided when needed. Training should be provided at least quarterly so that personnel will be aware of the requirements of the laws and regulations and can respond adequately to spill incidents.