United States Environmental Protection Agency
Region IX
POLLUTION REPORT

Subject: 

On March 12, 2008, EPA OSC Robert Wise, START and SBCo Petroleum visited the Greka Oil and Gas Williams B Lease Tank Farm.  The Williams B Tank Farm is an idle tank farm that was never brought into service by Greka.  The tank farm consists of six 10,000 gallon above ground storage tanks (ASTs), two 10,000 gallon Baker tanks, a horizontal heater treater and a vertical heater treater.  There was no secondary containment around the tank farm.  The tank farm is bordered on the west by a wash that drains into Cat Canyon Creek.  To the north of the site is Cat Canyon Creek.  Cat Canyon Creek drains to Sisquoc Creek, which drains to the Santa Maria River, which drains to the Pacific Ocean.

With the exception of horizontal heater treater all of the tanks contained petroleum material (liquid oil, oily sludge, oil water or oily tank bottoms).  All tanks except for the horizontal heater treater were actively leaking in multiple places.  The ground around the six 10,000 gallon ASTs was heavily saturated with oil.  The ASTs were missing man way covers, heavily corroded, and full of holes.  Several of the ASTs were also missing tops.  The vertical heater treater was actively leaking through a valve in the tank.  The horizontal 10,000 gallon Baker tanks contained a heavy asphaltic oil material and possibly water.  One tank contained oily sludge approximately three feet from the bottom.  This tank was heavily corroded above the oil line, had numerous holes, was open on the top, and was bulging on the ends and sides.  The second horizontal tank was 3/4 full and had a thick oil pad on the surface.

On March 19, 2008, OSC Wise issued a Clean Water Act 311(c) order to Greka for the William B Tank Farm.  The Order directs Greka to remove the oil from the tanks, demolish the tanks and remove soil contamination to a depth of three feet bgs.  

9/2/08 - 9/5/08
Work Performed:
• Roll-off bins (ROB) were prepared & lined with visqueen plastic sheeting; non-hazardous crude impacted solids were removed from Banker Tank A and placed into two ROB for disposal.
•  Mixed non-hazardous crude impacted soil in Banker Tank A
•  Excavated 1.5ft below ground surface (bgs) of soil from under Banker Tank B; no crude impacted soil observed at 1.5ft bgs
•  Removed side portal plate from Heater Treater.  Estimated volume of contents at ¾ level.

9/8/08 - 9/12/08
Work Performed:
• Removed upper ring Stock Tank “D” and began to mix non-hazardous crude impacted soils.
• Folded upper Stock Tank “D” ring, placed in scrap metal salvage bin for physical disposal.
• Baker Tank “A” non-hazardous crude impacted solids entirely removed and placed in 4 - 16 cubic ft & 2 - 20 cubic ft roll-off-bins lined with visqueen plastic sheeting for temporary storage and physical disposal.
• Baker Tank “A” physically removed from gravel platform for scrap metal salvage disposal.
• Heavy Crude removed from Vessel Sand Separator & Heater Treater was delivered to reclamation facility Bell injection.

9/15/08 - 9/19/08
Work Performed:
• Vacuum trucks completed removal of heavy crude from Vessel Sand Separator.  Transported 770 barrels extracted crude for injection to Bell Injection facility via vacuum truck.
• Injected 70 barrels hot water into Heater/Treater to facilitate crude removal.
• Soils mixed into Stock Tank “D”.
• Stock tank “A” was completely detached from battery platform.

9/22/08 - 9/26/08
Work Performed:
• Mixed non-hazardous crude-impacted soil in Stock Tank “F”.  All solid material in Stock Tank “F was removed and placed in visqueen-lined temporary storage containers.  Stock Tank “F” removed from battery platform.  Stock Tank “F” prepared for physical scrap disposal.
• Crude/water mixture removed from Stock Tank “C” using vacuum trucks and delivered to Bell injection facility via vacuum truck.  Mixed non-hazardous crude-impacted soil in Stock Tank “C”.  All solid material removed from Stock Tank “C” and placed in temporary storage roll-off bins in advance of disposal.  Stock Tank “C” was completely detached from battery platform.
• Removed solid material from Stock Tank “A” and placed in temporary storage roll-off bins in advance of disposal.
• Crude/water mixture removed from Heater/Treater and delivered to Bell injection facility via vacuum truck.

9/29/08 - 10/3/08
Work Performed:
• Removed all solid material from Stock Tank “D” and placed in visqueen-lined temporary storage containers.  Removed tank from battery platform and prepared for physical scrap disposal.
• Stock tank base rings removed from ground and readied for scrap disposal.  All metal structures were removed from stock tank battery soil.
• Top 12” of stock tank battery earth scraped off.  The non-hazardous crude-impacted soil was stockpiled at south end of the battery.  
• Stock tank soil sampled; samples sent to Zalco Laboratories for analysis.
• DemCon Salvage collected and removed scrap metal pipes and bins from stock tank battery site.
• 19 roll-off bins (14 from the stock tank battery and 5 from the Baker Tanks) are staged transportation to waste disposal facility.  

10/6/08 - 10/17/08
Work Performed:
• Removed small areas of crude oi-impacted soil on Williams B work site.
• Waste Management, Kettleman Hills Waste Facility, approved physical disposal of stock tank solids,
• Bob Tull, Williams “B” Demolition Site Supervisor, accompanied Steve Lowe, CUPA, and Matt Circop, SBCFD for site inspection at Williams “B” facility Tuesday, October 14, 2008.

10/20/08 - 10/31/08
Work Performed:
• Scraped stock tank battery platform to remove oil/asphalt layer discovered during walkthrough on 10/14/08.
• Bob Tull collected sample for fish bioassay on 10/23/08.  Samples sent to OEC Laboratories in Santa Maria for analysis to determine categorization of soil from stock tank battery platform.  
• Speed’s Transport removed 8 of 14 roll-off bins containing solids from stock tanks A-F.  Bins were transported to Kettleman Hills Waste Facility for disposal per Profile Number CA304042.
• Stock tank battery platform soil sample sent to OEC Laboratories for fish bioassay – “passed”.  Stock tank battery platform soils to be transported to and disposed at McKittrick Waste Treatment Site.

11/3/08 - 11/21/08
Work Performed:
• Speed’s Transport removed all remaining roll-off bins containing solids from stock tanks A-F.
• Four end dumps of Stock Tank Battery Platform soil transported to McKittrick Waste Treatment Site.

12/8/08 - 12/19/08
Work Performed:
• Transported four end dumps of Stock Tank Battery Platform soil to McKittrick Waste Treatment Site

The Final Work Plan has been posted to the Documents section of the website.  Planned removal actions include:
• Conduct pre-demolition permitting and characterization.
• Remove contents of the six ASTs, two Baker tanks, and two heater treaters.
• Demolish, transport, and dispose of the tanks.
• Excavate contaminated soil beneath the tanks and in other parts of the Site, and
backfill the completed excavations with clean imported soil.
• Transport and dispose of the tank contents and soil from excavation.
• Conduct post-removal sampling to confirm the cleanup of affected areas.
• Evaluate the two onsite production wells to determine if they pose a threat of
discharge, and to make repairs as necessary.

• Greka to conduct post-removal sampling to confirm the cleanup of affected areas under EPA/SBCFD oversight.
• Transportation and disposal of remaing roll off bin containing Baker Tank waste following approval confirmation sampling.
• Greka to prepare and submit Submit final report.

• Confirmation sampling was postponed due to inclement weather and wet ground conditions.  Greka will coordinate with EPA/SBCFD to reschedule.

A total of 21 Roll-Off Bins were transported for disposal to:
Waste Management - Kettleman Hills Facility
36251 Old Skyline Rd., Kettleman City, CA 93239

A total of 10 end dump loads were transported for disposal to:
McKittrick Waste Treatment Site
56533 HWY 58 West, McKittrick, CA 93251