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BP OIL COMPANY -3- 6 April 1992 <br /> finding. Also, Section 25270.8 requires the facility to immediately notify the <br /> city, county, and the Office of Emergency Services of a spill of one barrel (42 <br /> gallons) or more. These requirements must be stated in the SPCC plan. <br /> 29. Currently, storm water in the diked tank farm is contained within the tank farm and <br /> disposed of via evaporation. However, excess storm water may be discharged onto an <br /> adjacent empty lot north of the tank farm. If a discharge occurred, monitoring <br /> would consist of visual observation. The latter is inadequate to ascertain the <br /> absence of dissolved contaminants and, therefore, is not protective of surface or <br /> ground water quality. At a minimum, the discharge must be tested for aromatic <br /> hydrocarbons using U. S. EPA 602. If constituents are present then the storm water <br /> will need be treated to meet water quality objectives and BP will need to obtain an <br /> NPDES storm water permit prior to discharge. Other disposal alternatives include <br /> hauling it offsite for treatment and disposal or discharging it to the sewer. <br /> 32. See Comment No. 34 below. <br /> 33. The basis of the tank farm design is not described. Section 25270.5(d)(3) of the <br /> APSA requires containment for contents of the largest tank plus sufficient space <br /> for rainfall . The plan must specify the design criteria used in building the tank <br /> farm including how to protect ground water quality. <br /> 34. There is no ground water monitoring system. Section 25270.7(c) of the APSA states <br /> that if the Regional Board determines a facility poses a threat to ground water <br /> quality, the owner or operator of the facility shall do any of the following: <br /> a. Install a ground water monitoring system; <br /> b. Install and maintain a tank foundation design approved—by the Regional Board <br /> which will provide early detection of products stored before reaching ground <br /> water; <br /> c. Install a tank water bottom monitoring system; and <br /> d. Use other methods approved by the Regional Board. <br /> 37. See General Comment No. 3. <br /> 50. The inspection procedures are succinct and outlined in the inspection report form, <br /> which is attached to the SPCC plan. Inspection reports are maintained in a <br /> separate file but a copy of the reports should be included in the SPCC plan. <br /> 52. The training schedule is not specified. Training should be provided at least <br /> quarterly so that personnel will be aware of the requirements of the laws and <br /> regulations, and can adequately respond to spill incidents. <br /> SUMMARY <br /> Overall the facility is clean and well-maintained. However, the following items need <br /> to be addressed: <br />