Loading...
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