SITE INFORMATION AND CORRESPONDENCE

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BP OIL COMPANY -2- 6 April 1992 Spill Prevention Control and Countermeasure (SPCC) Plan Prior to the inspection, BP Oil sent us its Spill Prevention Control and Countermeasure (SPCC) Plan. My comments on the plan are provided in Table 2 and further explained below. General Comments 1 . The plan does not have a table of contents or pagination. Previous certifications, reviews, and recommendations should be placed in an appendix. 2. Attachments 1 through 3 are missing. 3. Attachment 4 shows some of the features of the facility, but it is very sketchy and includes penciled-in notations. The site map must be revised to include a conve- nient scale, facility drainage features, diked areas, facility equipment, storm water disposal area, and surface water bodies. Several maps may be necessary. Each map must have the north arrow pointing up. 4. Under Facility Drainage and Bulk Storage Tanks, the plan states that all storm runoff and plant effluents including tank bottom water go to the 10,000 gallon UGT. It also states that drainage in the diked area can be valved to this tank. The latter may not have adequate capacity to contain all the liquid going into it, even with the additional 17,000 gallons of storage from the transmix tank. Noncontact water should be diverted to minimize the quantity of wastewater that needs to be stored and disposed. The plan must delineate the amount of wastewater produced, show that there is storage available, and address the disposal of wastewater. 5. The section Facility Transfer Operations, Pumping, and In-plant Process states in part, "It is not known if buried pipelines are wrapped or coated to reduce corro- sion" . It is the facility' s responsibility to know if its buried pipes are wrapped or coated. Furthermore, Section 112.7(e)(3)(i) of 40 CFR states that buried pipes should be catholically protected if soil conditions warrant. Specific Comments The comments below are numbered according to the checklist numbering. 3. The plan is certified by a professional engineer registered in Ohio. This may be acceptable since there is no stipulation in Section 112 40 CFR or the APSA that the plan be certified by a professional engineer registered in the state where the facility is located. However, the engineer must be familiar with the requirements of the APSA. 13. See General Comment No. 3 above. 15. See Comment No. 33 below. 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