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P--G E 1 V E L JAN 06 2016 Summary of Violations MHONMENTAI I �r-A! 1..�F" Cp,MT!,17 IY Item#201—CFR 112.3(d) Plan certification by Professional Engineer(PE) missing or i �ncomplete The report alleges that the PE certification is incomplete because it is conditional on recommended "repairs" and PE certifications may not be conditional. Tesoro disputes this is a Class II violation.Tesoro maintains there is no violation. The PE certified the SPCC Plan ("Plan")on November 8, 2013 as required by 40 C.F.R. § 112.3(d). The certification was not conditional and considered all of the aspects of§ 112.3(d)(1). Tesoro has completed the recommended actions at Section 2.1 of the Plan. Gravel was removed by facility personnel shortly after receipt of the Plan and, as discussed below for Item # 609, remaining fill work is complete. Tesoro has revised its Plan to address these issues. A copy of the Plan amendment pages and accompanying certification are enclosed. Item#301—CFR 112.5(a) Failed to amend Plan as necessary 1. The report alleges that page 19 of the Plan was not properly amended to identify the 6,000-gallon UST and underground piping associated with Dike 2 overspill containment. Tesoro disputes this is a Class II violation. Tesoro maintains that there is no violation. Table 2, note 2 of the Plan identifies the appropriate Dike 2 containment. Tesoro has corrected the inadvertent misprint on page 19 of the Plan as reflected on the enclosed Plan amendment pages. 2. The report alleges that the "Premium 20 Gasoline"tank has been out of service for more than 6 months and the Plan was not properly amended. Tesoro disputes this is a Class II violation. Tesoro maintains there is no violation. Tesoro is required to amend its Plan when a facility change "materially affects [the facility's) potential for a discharge." § 112.5(a). The "Premium 20 Gasoline"tank was emptied and taken out of service for repairs; the tank remains empty while options are being evaluated. The empty tank does not "materially affects [the facility's] potential for a discharge." Consistent with the Plan,Tesoro is using Tank 1700 for premium gasoline storage. Nonetheless, subsequent to the County's inspection,Tesoro amended its Plan and added signage to the tank to note it is out-of-service. A copy of the Plan amendment pages are enclosed. Item #604—CFR 112.7(a)(3) No facility diagram or didn't show location and contents of containers, transfer stations,and pipes. The report cites Tesoro for failure to show the 6,000-gallon UST and underground piping associated with Dike 2 overspill containment on the facility diagram. Tesoro disputes this is a Class If violation. Tesoro maintains that there is no violation of the facility diagram requirement. First, the 6,000-gallon tank is properly classified as an "underground 6,000 gallon double wall sump tank" ("Sump"). Tesoro's Plan does not refer to the tank as a UST because the Sump remains empty except during emergencies, and then is promptly emptied into Tank 420. See 40 C.F.R. §280.10(b)(6); HSC 1