Laserfiche WebLink
the deviation from this. Since it is unclear what the industry standard being used to comply with CFR 40 CFR 112.8(c)(6) <br /> is, it is only assumed that the reference to section 8.0 would incorporate the STI-SP001 standard. If this is the case,the <br /> discussion for CFR 40 CFR 112.8(c)(6) does not meet the requirements outlined in the standard.There is no other <br /> mention of an industry standard in the plan. <br /> Per SPCC Guidance for Regional Inspectors,Version 1.0, November 28, 2005 if an owner or operator deviates from <br /> applicable industry standards to develop an integrity testing program,then a PE must certify an environmentally <br /> equivalent alternative in the SPCC Plan.The Plan must provide the reason for the deviation, describe the alternative <br /> approach, and explain how it achieves environmental protection equivalent to the applicable industry standard. <br /> Guidance document can be found at the following site. See page 7-42 and 7-43 Scenario 3: Elevated large shop-built <br /> containers. <br /> https://www.epa.gov/oil-spills-prevention-and-preparedness-regulations/spcc-guidance-regional-inspectors <br /> Feel free to call with any questions. <br /> FREE classes presented by NES Inc. are available to all San Joaquin County Hazardous Waste, Underground Storage Tank, <br /> and Aboveground Petroleum Storage Facility Business Owners and Operators. List and schedule of classes can be found <br /> here. <br /> Thank you, <br /> Cesar Ruvalcaba <br /> San Joaquin County Environmental Health Department <br /> Environmental Health Specialist <br /> 1868 East Hazelton Ave <br /> Stockton, CA 95205 <br /> 2 (209) 953-6213 8 (209) 464-01381 2 cruvalcaba@sicehd.com W <br /> SAN JOAQUIN <br /> " r*k COUNTY <br /> MW <br /> �key Greatness grows pert. <br /> From: Cameron J. McGovern <cjmcgove@up.com> <br /> Sent:Thursday, November 8, 2018 2:38 PM <br /> To: Cesar Ruvalcaba [EH] <cruvaIca ba@sicehd.com> <br /> Subject: Re: ASPA/SPCC inspection report- 1000 Roth Rd, French Camp - PR0523352 <br /> Mr. Ruvalcaba, <br /> Thank you for conducting the SPCC Inspection of Union Pacific Railroad's (UPRR) French Camp Intermodal Yard on <br /> Friday, October 26, 2018. For your convenience, I have attached to this email the inspection report with the signed return <br /> to compliance (RTC) form, dated November 8, 2018. <br /> Per the County's findings, UPRR will address the following alleged items with the below responses: <br /> Item#301 <br /> CFR 112.5(a)Failed to amend Plan as necessary. <br /> Approximately three 55 gallon drums containing product regulated under APSA were observed inside the garage area near the east wall.That storage location of <br /> the drums is not addressed in the SPCC plan.The Spill Prevention,Control,and Countermeasure(SPCC)Plan must be amended when there is a change in the <br /> facility design,construction,operation,or maintenance that materially affects its potential for a discharge,within 6 months of the change,and implemented as soon <br /> as possible,not later than 6 months following preparation of the amendment. Immediately make all necessary amendments to the SPCC Plan to accurately <br /> represent the procedures and policies currently in place at the facility. <br /> This is a minor violation. <br /> 2 <br />