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GEOMATRIX In 1988, Simplot discontinued the wastewater storage,cleaned out the tanks, and continued to use Tank 127 for storing stormwater. In 1989, Simplot cleaned out piping appurtenant to the tanks. In 1991, Simplot converted Tank 127 for use in storing fertilizer. ' In 1993, the DISC issued Simplot a Report of Violation that indicated the former hazardous waste storage tanks had not been closed in accordance with current requirements (DISC, 1993). ' Simplot responded to the Report of Violation by transmitting documentation concerning the tank cleanout activities and the current tank status (Simplot 1994a). In addition, Simplot and DTSC entered into a Consent Agreement (DISC, 1994) to complete closure of Tanks 127 and 128. 1 2.4 Tank and Piping Construction ' Tanks 127 and 128 are located near the sbutheast corner of the existing Lathrop plant, as shown on Figure 2. The tanks are constructed similarly with welded, heavy-gauge steel plate bottom, ' walls, and top, except that the top of 128 has been removed. The dimensions are as follows: Tank 127 Tank 128 30 feet in diameter 30 feet in diameter 30 feet tali 30 feet tall 150,000 gallon capacity 150,000 gallon capacity Concrete beam foundation Concrete beam foundation Tank top Tank top removed Secondary containment berm Secondary containment berm The tank area includes a secondary containment structure that surrounds the two tanks described ' above and three other fertilizer product storage tanks. The secondary containment structure consists of earthen berms, an asphalt/concrete sealed floor and bene walls, and a stormwater ' collection sump. Appurtenant piping for Tank 128 is welded or flanged carbon steel and is located aboveground ' on pipe racks. Wastewater that was generated during cleanout of the formulation tanks was transferred for temporary storage via this piping. ' Appurtenant piping for Tank 127, previously consisted of underground piping that drained via gravity from stormwater collection drains and aboveground piping for pumping stormwater from ' the rail car loading facility Iocated in the northwestern portion of the Lathrop plant. The stormwater collection drains flowed into a concrete-Iined sump that originally contained a float- actuated pump for transferring water into the tank. During the 1988 cleanout of the tanks,water was transferred back through piping that connects Tank 127 and the rail car Ioading facility. Wastewater flowed from the tanks into rail cars for transport to an off-site hazardous waste 4