SITE INFORMATION AND CORRESPONDENCE

Home Browse Search

STATAE OF CALIFORNIA- Environmental Prot Agency PETE WILSON, Governor CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARDOQ CENTRAL VALLEY REGION �JR�3543 Routier Road, Suita A IM IF � 11 Sacramento, CA 95827.3098PHONE: (916) 255-3000 FAX: (916) 255-3015 SFr^ 28 1994 27 September 1994 ENW "'WIENTAL HEALTH PE .40/SERVICES Mr. Jerry Tucker Spreckels Sugar Company, Inc. 18800 S. Spreckels Road Manteca, CA 95336 SOIL CONTAMINATION AND SPCC PLAN, SPRECKELS SUGAR COMPANY, MANTECA PLANT, SAN JOAQUIN COUNTY We are in receipt of your 28 July 1994 letter and attachment from Mr. John Minney, Consulting Engineer. In our 15 June 1994 telephone conversation, I requested that you amend your Spill Prevention Control and Countermeasure (SPCC) plan to state that you will report to us all spills which pose a threat to water quality, regardless of the amount and . location of the spill. Your 16 June 1994 letter included a revised page 5 of your SPCC plan which appropriately changed the language regarding the spill quantity, but continued to state that only spills outside of the containment area would be reported. My 8 July 1994 letter again requested that the SPCC plan be changed to include the reporting of spills inside the containment area. Your 28 July 1994 letter states that you will not report any spills which occur inside of the containment area. Considering the fact that the containment area for your aboveground storage tank is unlined, there is essentially no difference with respect to ground water quality threat, if a spill occurs inside or outside the containment area. Section 13267 of the California Water Code states that ". . . the regional board may require that any person discharging . . . waste . . . that could affect the quality of waters within its region shall furnish, under penalty of perjury, those technical or monitoring program reports as the board may specify". Since ground water in the area is typically close to the surface, we consider most spills into the soils as potential threats to ground water quality. Health and Safety Code 25270.7(c) allows the board to require owners or operators of tank facilities such as yours to "install a ground water monitoring system which will detect releases of petroleum into the ground water", Instead of requiring you to install monitoring wells now, we have used our discretion to require you only to report all petroleum spills which threaten ground water quality (regardless of amount or location). If a spill occurs which threatens ground water quality, monitoring wells may be required at that time.