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AUG-14-99 09 :02 AM Sohn M Cruikshank 310 329+4143 P. 03 08/14/99 J?Vi& Onyx Industrial Services,Inc. Page 2 COMPLIANCE ASSESSMENT CCR Title 21 Section 66164.175 Containment (a) Container Iransfer and storage areas shall have a containment system that is designed and operated in accordance with subseerinn (b) of this section. (b)A containment system shall be designed and operated asfollows: (1) a base shall underlie the containers which is free of cracks or gaps and is sub ciendy impervious to contain leaks, spills, and accumulated precipiration until the collected material is detected and removed,- OMI emoved,OM1 shall thoroughly inspect the polyethylene liners and the container wall framing for integrity prior to putting them in service. This will assure that the secondary containment system will not leak. (2) the base shall be sloped or the containment system shall he otherwise designed and operated to drain and remove liquids resulting from leaks, spills or precipitation, unless the containers are elevated or are otherwise protected from contact with accumulated liquids; The braced wood frame design lined with the tarp will hold any leaks or spills until they can be safely removed. Accumulated liquids will contact the containers,but the operation of the TTU requires an operator on-site full time. Therefore,any accumulated liquids will be removed in a timely manner, thus minimizing the container/liquid contact time. (3) the containment system shall have sufficient capacity to contain precipitation frons at least a 24- hour, 25-year storm plus 10%(if the aggregate volume of all containers or the volume of the largest container, whichever is greater. Containers that do not conlain free liquids need not be considered in this determination: Up to rive containers of equal size could be in the secondary containmenrdevice at any given time. Each container holds up to 500 barrels, or 15,750 gallons. Ten percent of the maximum volume is 1,575 gallons. Inside the secondary containment area, which is 40 feet by 60 feet and 16 inches high, 1,575 gallons would rise VA inches, leaving 11 '/, inches available for precipitation. This is well abuve the expected rainfall in a 24-hour, 25-year storm. Based on this analysis, the single tank maximum capacity is the worst case scenario. The 23,975-gallon berm has sufficient capacity to contain all 15,750 gallons in the container. (4) run-on into the containment system.shall be prevented unless the collection system has sufficient excess capacity in addition to that required in subsection (b)(3) of this Section to contain any run-on which might enter the.system; and The wood sidewall design of the secondary containment device and aboveground operation prevents run-on. (5)spilled or leaked waste and accumulated precipitation sholl be removedfrom the sump or collection area in as timely a manner as is necessary to prevent overflow of the collection system.If the collected material is a hazardous waste under chapter 11 of this division, it shall be managed as a hazardous waste in accordance with all applicable requirements of chapters 12 through 16 of this division. If the collected material is discharged through a point source to waters ojthe United Stales, it is subject to the requirements ufseclion 402 of the Federal Clean Water Act, as amended(33 U.S.C. section 1341). Apparently OMI has a written inspection checklist that must be completed every hour during the treatment process_ This assures that any leak would be identified in a timely manner. Should a