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Wendy Cohen -2- 26 March 1992 to regulate flow of western and southern damage. water from one section to another. The berms surrounding the sides of the upper containment area appear to have some erosion I noted several puddles in both containment areas. The puddles may have been from recent rainfall or the high water table (the water table varies from about two feet to ten feet below ground surface). There was no evidence of an oil sheen or discoloration in any of the puddles. I reviewed the SPCC Plan kept on site. My comments on the plan are provided in Table 2 and summarized below. The comments are numbered according to the checklist numbering. 5. Emergency phone numbers were not listed (Ms. Cargill added this at the time of my inspection). 26. There was no discussion of applicable state laws. 34. There was no discussion of the ground water monitoring system. 50. Maintenance inspection reports were not initialed or signed by the inspector nor were they included in the plan. 52. There was no record of employee training attached to the plan. However, subsequent submittals showed the training is adequate. Some changes at the facility which will be noted in the revised SPCC Plan are the addition of two new storage tanks, the discontinued use of one of the three oil/water separators, the addition of a carbon treatment system for effluent from the two remaining oil/water separators, and the conversion of one storage tank from leaded to unleaded plus gasoline. Although this facility appears to fairly well-maintained, I have some concern related to the protection of ground water quality. Two oil/water separators at the site process water from the water draws at the bottom of the tanks and trick washing operations. This treated water plus stormwater from all areas of the plant are discharged to the unlined stormwater pond (the lower containment area) which is less than five feet above the water table. The same area is used for secondary contain- ment. The use of an unlined pond overlying shallow ground water for discharges of stormwater and treated wastewater is a threat to ground water quality. Although the capacity of the lower containment area (2,436,000 gallons) is large enough to contain the contents of the largest tank (2,100,000 gallons), it is questionable if it is large enough to contain the contents of the largest tank plus wastewater discharges and stormwater. During times when wastewater is in the pond, the secondary containment capacity for spills is compromised. Furthermore, it is likely that no matter how quickly any spills or leaks from the tank area are cleaned up, any petroleum -contaminated water discharged to the upper or lower containment area will reach ground water.