HomeMy WebLinkAbout1995-03-08 Correspondence to BOD _ Unocal Energy Resourt"livision
Unocal Corporation
9645 Santa Fe Springs Road,P.O.Box 2212
Santa Fe Sprin s,California 90670
Telephone(310�946-6252
Facsimile(310)946-6241
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
U N OAL® Z 078 583 300
SENT VIA FAX
(714) 962-0356
Oil 5 Gas operations
Las Angeles Basin
March 3, 1995
CSDOC Board of Directors, District 11
c/o Ms. Penny Kyle, Board Secretary
County Sanitation Districts of Orange County
10844 Ellis Avenue
Fountain Valley, CA 92728
RE: Urgent Temporary Authorization Request Temporary Authorization Request
Special Purpose Discharge Permit
Unocal's Ft. Apache Site
Huntington Beach, CA
Dear Board Members:
This is a formal request to the Board of Directors of the County Sanitation Districts of Orange
County (CSDOC).
Unocal requests that the board make a recommendation to the Source Control Manager of the
CSDOC, that a temporary authorization be issued to Unocal to discharge storm water run-off
from their Platform Eva and Fort Apache facilities, due to the extenuating circumstances that
were outlined for Ms. Mahin Talebi, Source Control Manager, in a Unocal correspondence dated
March 3, 1995 (copy attached).
Please be advised that this is only a temporary authorization while the CRWQCB, the CSDOC
and/or the CSDOC's Board of Directors work with Unocal to help resolve the concerns and
mitigate the current dilemmas facing Unocal, regarding its Fort Apache Site, as it relates to the
facility's storm water discharges.
Meg.,M.o 3 BovE W Olredaa,DIMfld 11
,18A5
uses x
Thank you in advance for your prompt consideration and approval of this request.
If you have any questions or comments, please feel free to call me at (310) 946-6218.
Respectfully submitted,
Xonie B. Lloyd
Environmental Supervisor
XBUcdI
NEWIRICORRE5690 71XL
Enclosure
cc: (w/o Enclosure)
M. Talebi, CSDOC
M. Adackapara, CRWQCB
G. Bennett - Venture
V. W. Orr
T. Collier
Corporate Audit File c/o J. Cronk - Ventura
CSDOC Correspondence File
Ft. Apache Special Purpose Discharge File
X. B. Lloyd Correspondence File
Unocal Energy Raseurc�p,Divieion
Unocal Santa
Fe Springs
Sant Same Fe Springs Rn. ..P.O.60x 2212
Santa Fe Sptin s,California 90670
Telephone 1310�948-8262
Facsimile(310)946.6241
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
UNOCALO
Z 078 583 296
SENT VIA FAX
(714) 962-6957
onaa-opreHenc
Mcaoa Bceln March 3, 1995
Lac
County Sanitation Districts of Orange County
10844 Ellis Avenue
Fountain Valley, CA 92728
Attn: Ms. Mahin Talebi
RE: Storm Water Handling Crisis
Special Purpose Discharge Permit Denial
Concerns&Dilemmas of Present Situation
Dear Ms. Talebi:
As you are aware, per our telephone conversation on Friday, February 24, 1995, Unocal is
currently caught in an environmental compliance dilemma.
This correspondence is being made in an attempt to depict some of the current dilemmas which
are presently confronting Unocal and to highlight some of Unocal's major concerns. It is by no
means intended to be all inclusive of all of the factors or issues that are pertinent to this
particular topic. Hopefully those can be evaluated and discussed in the near future.
The District's (County Sanitation Districts of Orange County or CSDOC) denial of Unocal's
request for a Special Purpose Discharge Permit (Special Permit), which my office received on
Friday, February 24, 1995, caught us by surprise and has placed Unocal in a very problematic
situation.
Unocal has been anticipating approval of this permit. We understand that the more submittal
of Unocal's request (and your subsequent review)does not automatically imply that an approval
will be granted, however, this Special Permit request has been pending with your office for some
time.
You will recall that Unocal's request for a Special Purpose Discharge Permit was submitted to
your.offlce in May of 1993, after you and Mr. Brian Deagle pointed out the fact to Unocal that
the discharge of storm water run-off to your system was allowed under certain circumstances If
a"Special Purpose Discharge Permit"had been authorized, pursuant to the District's Wastewater
Discharge Regulations (Discharge Regulations), dated February 7, 1992.
At the District's request, we mailed your office "Additional Information" (dated December 30,
1994) to further facilitate CSDOC's evaluation of Unocal's Special Permit request.
W.M hTWW.MD
M 3,IM
Pp 2
On January 17, 1995, Mr. Tom Walker called with some additional questions. Mr. Walker also
informed me that, to date, no Special Purpose Discharge Permits for rainwater discharges had
been issued,since the increased rainwater volumes decreased the effectiveness of the District's
sewage treatment facilities, and that the District did not want to set a precedence for industries
to obtain the Special Permits for rainwater discharges. I reiterated the fact that Unocal had
special extenuating circumstances that should warrant the approval of the Permit. Mr. Walker
said that it would need to be discussed with you upon your return to the office some time in
February. I assumed that Unocal would have had the opportunity to discuss the District's
concerns in person, before a final determination was to have been made.
Your letter of denial was received by my office on a Friday afternoon, with rains scheduled to
fall on the upcoming Monday. As I discussed with you on the phone that Friday, this has put
Unocal in a very precarious situation. Since the District's letter did not allow any time for us to
comply with your denial, (i.e., immediately cease discharge of storm water run-off to the
CSDOC's sewer system), Unocal currently has no other means of"legally"discharging this
water.
Disallowing storm water discharges to CSDOC's system poses the following challenges:
1. Increased environmental liabilities for Unocal if a spill were to occur while Unocal
was discharging to the county's storm drain/flood control channel.
2. Mitigating the rain at the site, by installing a roof over the facility, is not possible
(without some city variance or amendment), since the roof would be in violation
of Unocal's existing Use Variance Permit(No. UV-5247), issued by the County of
Orange in 1963. (Note: In 1966, when the property was annexed to the City of
Huntington Beach, the Variance Permit was amended with a condition by the city
(condition #4), stating: "No structure shall project above the wall.")
a. Please be advised, since gas and oil is processed at the facility, any leak
would emit gases which would create an explosion hazard. Consequently,
any type of roof placed over the facility would have to extend at least 5 to
10 feet over the wall to mitigate safety concerns, regarding the risk of
explosions.
b. In addition, I doubt very seriously that the homeowners adjacent to the
Fort Apache Facility would want a highly visible roof over the facility.
C. In addition, it may be impractical to separate the storm water run-off from
the "wash-down" water on the platform, or to isolate the storm water from
the spill containment facilities on the platform.
Immediately upon receipt of your denial, I contacted the State Water Resources Control Board
(SWRCB) in Sacramento and the California Regional Water Quality Control Board (CRWQCB)
in Riverside and was able to obtain an application package to discharge our storm water to the
storm drain system by filing an N.O.I. (Notice of Intent), which will allow storm water discharges
under the State's General NPDES Permit (No. CAS000001).
W Whin TOIeW,CSWC
""3.1995
Pape 3
There are several challenges, however.
1. Technically, before any discharges can be initiated under the General NPDES
Permit, all dischargers must develop and implement a Storm Water Pollution
Prevention Plan (SWPPP) and a Discharge Monitoring Program. Unocal is
hopeful that a grace period can be granted by the CRWQCB, regarding the
development and implementation of these requirements.
2. This General Permit cannot cover Platform Eva, since it already has a point-
source NPDES permit, authorized under the CRWQCB's Order No. 91-28.
Unfortunately, however,this permit does not have provisions to allow storm water
discharges from the platform and must be amended.
3. Furthermore, and of more significant concern to Unocal, are the environmental
risks the surrounding neighborhood will be exposed to in the future, as storm
water is discharged into the adjacent flood control channel. This channel empties
Into Huntington Harbor, which is just several blocks away. If there were to be
some type of operator error or if an equipment malfunction were to occur at this
facility during those times when discharging rainwater to the flood control channel,
there is the risk of released oil being directly pumped Into the harbor, and
subsequently into the ocean at Boise Chica Beach. This is an unnecessary
increased risk for this community and an undesirable increase in Unocal's
environmental liability exposure, since the current design of the existing
containment facilities constructed at the site precludes any fluids from exiting the
location, including rainwater.
As I indicated in the "Additional Information" submitted to your office at the
beginning of the year, "the containment areas provide secondary containment for
the oil processing facilities and the oil shipping tanks at the site. The collected
rainwater from the platform and the facility's site Is pumped into Me
processing system and is also treated with the production in the oil-water-gas
separation equipment at the site. ... UnocaPs water pretreatment facilities
process the produced water and rainwater runoff prior to discharging the
stream into to the District's sewerage system."
Unocal has attempted to demonstrate to the District that the Fort Apache Site
processes the storm water run-off through existing production processing facilities.
In the "Additional Information" it was also noted that: "No additional regulated
contaminants will be introduced into the District's sewage system."
Currently, the existing contaminant constituents discharged to the District are
consistently below the District's existing permit limits.
4. Finally, the most pressing challenge is the fact that it will take some time to
address and/or implement all of the above issues.
M1k.MNN Tebp,MINX
W"J,IN5
P.,6
Recommendation(s)
SHORT RANGE:
Temporarily authorize Unocal to dischargestorm water to the CSDOC's sewersystem and
provide Unocal the opportunity to sit down and discuss this matter with the appropriate
personnel at the District in more detail, so that we can demonstrate, to the satisfaction of the
District, that a Special Purpose Discharge Permit should be granted pursuant to Article 3, Section
305, Subpart C of the District's Discharge Regulations, since: "no alternative method of
disposal is reasonably available, or to mitigate an environmental risk or health hazard:'
LONG RANGE:
Option I (Unocal's preference)
Unocal can minimize approximately one-third of the amount of storm water that will be
discharged to your sewer system by installing water injection facilities on Platform Eva.
During the rainy season, the injection volume of rainwater from the platform will average
approximately 53 barrels per day. These injection facilities will allow Unocal to not only
inject the platform's rainwater into wells offshore, but also a substantial amount of the
platform's produced water (approximately 2,000 - 4,000 barrels per day). This will
significantly reduce the total amount of water sent to the District all round. In
fact, Unocal will be offsetting the volume of rainwater that it sends the CSDOC by
more than a factor of four.
Note: This project is currently in progress, and its completion is anticipated by the
end of the summer (pending receipt of all of the remaining permits and
authorizations), well in advance of next year's rainy season.
In addition,approve Unocal's Special Purpose Discharge Permitrequestto allow the
storm water at the Fort Apache Site to continue to be discharged to the sewer
system(an average of only 35 barrels per day approximately). The associated drainage
area is only 145' x 175'. This is not a significant volume of rainwater, especially
when considering the fact that four to five times this amount will be offset by
injection, as proposed above.
Option II
In addition to the option above, Unocal would continue to fully develop and implement the
N.O.I. (Notice of Intent), mailed February 25, 1995 to the State Water Resources Control
Board, which will allow storm water discharges under the State's General NPDES Permit
(No. CAS000001). Then during regularly manned (daylight) hours, divert rainwater
discharges to the storm drain channel.
W MMIn Tbbbl.Crypt
M.ra b,Im
P.g.b
Please be advised that the Option I proposal mitigates Unocal's environmental concerns
associated with storm drain discharges during upset conditions at its onshore facility. This is
critical to minimizing the company's future environmental risks and liabilities.
The Option I oroposal also reduces the overall volume of water discharged to the CSDOC,
including rainwater. This offset in volume mitigates the District's concern regarding its treating
facility's effectiveness of handling sewage and industrial waste water during the rainy season
(based upon capacity).
The Option II proposal, however, still has all of the immediate challenges discussed above, but
it will only mitigate an Incremental average of merely 11 barrels (462 gallons) per day of
rainwater from going to the sewer system (based on daylight discharges of the onshore facility's
rainwater to the storm drain).
Unocal believes that Option II is by no means worthwhlielll
Upcoming Activities
Per our telephone conversation on Friday, February 24, 1995, 1 am planning to discuss
the above items with you and other representatives from the CSDOC and the Regional
Water Quality Control Board at a meeting tentatively scheduled for Thursday, March 9,
1995, at the CSDOC's office.
In addition, please be advised that based upon the items discussed above, on March 8
at the board meeting, Unocal will also make a request to the Sanitation District's Board
of Directors to instruct the CSDOC to, at a minimum, temporarily authorize Unocal to
discharge storm water to the CSDOC's sewer system while our staffs work together
to identify and agree upon the most practical and viable solution. If, however, this
temporary authorization can not be granted (based on circumstances unknown to
Unocal), then at least temporarily allow unauthorized discharges to the District's sewer
system without pursuing any enforcement activities or subjecting Unocal to any civil or
administrative penalties, while these issues are resolved.
In closing, I wish to reiterate the fact that Unocal is still committed to its original position, and
continues to firmly believe, that if you consider all of the alternative disposal methods proposed
and/or considered by both Unocal and the District, and review each aspect of each alternative,
regarding feasibility, practicality, risk, and the costs and consequences associated with
implementing and maintaining that particular alternative, that Unocal's historical and proposed
method of handling the storm water runoff at the Fort Apache Site is still the most practical and
prudent method of disposal for all parties involved,which includesthe surrounding neighborhood,
the nearby community of Huntington Harbor, the California Regional Water Quality Control
Board, Unocal, and Indirectly, the County Sanitation Districts of Orange County.
10-1 /-ft
Ms.M h Ta .C WC
Marts 9,1996
Page 6
1 wish to thank you in advance for considering these issues. I look forward to discussing this
topic with you and other representatives from the CSDOC and the CRWQCB in more detail, on
Thursday, March 9, 1995, as we previously discussed.
If you have any questions or comments, please feel free to call me at (310) 946-6218.
Respectfully submitted, /111
6
on B. Lloyd
Environmental Supervisor
XBUcdl
es WMCO�%M"71ra
cc: M. Adackapara, CRWQCB
T. Walker, CSDOC
J. Tran, CSDOC
C. Pelletier, CSDOC
D. Nguyen, OCEMA
G. Bennett -Ventura
V. W. Orr
T. Collier
R. Speer- SITE COPY
Corporate Audit File do J. Cronk - Ventura
CSDOC Correspondence File
Ft. Apache Special Purpose Discharge File
X. B. Lloyd Correspondence File