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Oil Program 75 Hawthorne St., ENF-3-2 San Francisco CA 94105 415 972 3089 fax 415 947 3519 Repan oil or chemlcal spills at 800-A24-8802 From: Witul,Janice Sent: Wednesday, September 05, 2018 11:07 AM To: 'caseylrogers@aol.com' <caseylrogers@aol.com>; 'bevkent09 @sbcgloba 1.net' <bevkent09@sbcgloba1.net> Cc: 'cruvalcaba@sjcehd.com' <cruvalcaba@sicehd.com> Subject: RE: Union Point SPCC Plan My review of the SPCC Plan that was prepared for Union Point Marina has noted the following areas of non-compliance with the Oil Pollution Prevention requirements of 40 C.F.R. 112 - 4 0 G�A R. 14 2.22 Q-4 means 901 ef any kind 9F in any feFm, including, but not limited te: fats, 901, 9F greases ef animal, , greases,er marine mammal eFigin; vegetable eels, including eils fFern seeds, nuts, fruits, 9F kernels; and, ether gals and 0 neluding petroleum, f6iel 941, sludge, synthetie eel, mineral eels, 901 refuse, or eel mixed ;Agith ;Ag-astes ether than dredges k I_IR6A_R PA_6Rt-SPr-.r-. PlaR *_9 h_a_9P_C_I A_R a Af eil ether than that fe-ind 40 G F R 112 If there ;arp rARtA6RPrq 5151 gallens eir greater ef nen petireleurn, new er waste eils 9F girease-s a-s-se-ciated with the Marina 9F Grill,they sheuld be aCICIPCI to the coCr oi.,R 40 G.F-.R. 112.6(G)(1) requires that_an evdner or eperater v.dhe de-e-S net prepare a self-certified Plan must prepare and mplement a Plan meeting the general Plan requirements in §112.7 and applicable ,equi.e...—its in subparts B and C, neluding having the Plan certified by a Prefesswenal Engineer as required under§112.3(d). Union Point SPGG Plan is net by a Professional Engineelr4PE+- 40 C.F.R. 112.7(a)(3)(i) requires that the SPCC Plan address the type of oil in each fixed container and its storage capacity. Union Point SPCC Plan variously describes the facility has having: one 2000-gallon storage tank; a 1,000 gallon#2 diesel tank and a 1,000 gallon gasoline tank; a 10,000 gallon fuel tank; lube oils; and used oils. Used cooking oil tank has been added to Plan; tank location, secondary containment, inspections, and transfer/disposal of contents are not addressed. 40 C.F.R. 112.7(a)(3)(ii) requires that the SPCC Plan addresses discharge prevention measures including procedures for routine handling of products (loading, unloading, and facility transfers, etc.) Union Point SPCC Plan instructions for loading, unloading and transfer of oil include require that "The qualified person must have an unconstructive view of the cargo tank and delivery hoses". This instruction is contrary to best management practices,which require that such an attendant have a clear view of the equipment and process. 40 C.F.R. 112.7(a)(3)(vi) requires that the SPCC Plan include a contact list and phone numbers for the facility response coordinator, National Response Center, cleanup contractors with whom you have an agreement for response, and all appropriate Federal, State, and local agencies who must be contacted in case of a discharge as described in §112.1(b). 2