SITE INFORMATION AND CORRESPONDENCE_1988-1993

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MEMORANDUM CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD - CENTRAL VALLEY REGION • 3443 Routier Road, Suite A Phone: (916) - Sacramento, CA 95827-3098 -5600 ATSS Phone: 8-495495-5600 TO: Wendy L. Cohen FROM: Philip S. Isorena Senior Engineer Sanitary Engineering Associate DATE: 3 June 1992 SIGNATURE: {11,,x2,,; Z SUBJECT: COWENTS ON SHELL'S RESPONSES TO OUR SITE STATUS REVIEW AND FACILITY INSPECTION, SHELL OIL COMPANY, STOCKTON FUEL TERMINAL, SAN JOAQUIN COUNTY I have reviewed Shell 's 16 April and 8 May 1992 responses to our 23 March and 15 April 1992 letters. My comments below are in the same format presented in our and Shell 's letters. Facility Inspection Item 2: Section 112.7(e)(2)(iii) of 40 CFR states in part that drainage of rainwater from the diked area into a storm drain may be acceptable if inspection of the runoff rainwater ensures compliance with applicable water quality standards and will not cause harmful discharge as defined in 40 CFR 110. Visual inspection is not adequate to determine whether dissolved petroleum product constituents, namely total petroleum hydrocarbons in the • diesel or gasoline range (TPHD/G), benzene, toluene, ethylbenzene, or xylene (collectively BTEX) , are present in the storm water discharge. Thus, visual inspection will not ensure compliance with applicable water quality standards. Shell has stated that past monitoring has shown the absence of TPHD/G and BTEX, but we do not have those data, and this does not guarantee that future discharges will be free of these contaminants. SPCC Plan Review Item 5: 40 CFR 112 currently does not require emergency telephone numbers to be included in the SPCC plan. However, since the plan establishes procedures to prevent the discharge of petroleum products or its fractions into navigable waters of the United States, it only makes sense to include your contingency plan, which does include the emergency telephone numbers, in the SPCC plan. Most facilities with contingency plans have incorporated the latter into their SPCC plans. In fact, the U.S. EPA is recommending that the Oil Pollution Prevention Regulations be revised to require inclusion of contingency plans in facility SPCC plans. Item 26: 40 CFR 112.7(e) clearly states in part that sections of the SPCC plan "should include a complete discussion of conformance with the following applicable uidelines, other effective spill prevention and cntainment o procedures ?or, if more stringent, with State rules, regulations and guidelines)". The Aboveground Petroleum Storage Act (APSA) requires aboveground tank facilities to file a storage statement and associated fee every two years, prepare and implement an SPCC plan by 1 January 1991, and • establish a monitoring program a year after notification by the appropriate Regional Board. In addition, facilities are required to report to the appropriate Regional Board within 72 hours of positive findings in the monitoring program, or report to the county and city in which the facility is located any spill or release of one barrel or more into any waters of