COMPLIANCE INFO_PRE 2019 - Laserfiche WebLink

Home Browse Search

§ 25281(y)(1)(C). To avoid future confusion,Tesoro has amended its Plan to refer to the Sump as the underground 6,000 gallon double wall sump tank. Second, as pertinent here, the facility diagram requirement only applies to devices used for "storage"of oil. 40 C.F.R. § 112.7(a)(3). The Sump does not store oil as reflected by its exemption from UST requirements. Finally, consistent with the requirement of 112.7(a)(3),the Plan does describe the facility, including the Sump. A copy of the Plan amendment pages that reference the 6,000 gallon sump tank are enclosed. Item#609—CFR 112.7(c) Failed to provide secondary containment,diversionary structures, or equipment to prevent discharge. The report cites "cracking" and "concrete chipping" in the Dike 1 containment wall in the vicinity of the "30 ULSD"tank. At the time of the inspection, Dike 1 was"capable of containing oil" and "constructed so that any discharge from a primary containment system, such as a tank, will not escape the containment system before cleanup occurs." § 112.7(c). EPA's SPCC Guidance for Regional Inspectors at 4.2.2 states that secondary containment structures are "sufficiently impervious" as long as they allow for the cleanup of a spill to occur in time to prevent a discharge. There is no evidence that Dike 1 was not sufficiently impervious to contain oil. Nonetheless,following the November 4,2015 inspection, Tesoro examined the Dike 1 containment wall. The chip identified in the inspection photo was repaired. Any remaining cracking was addressed with concrete and mortar filler. Item#614—CFR 112.7(f)(1) Failed to train personnel on discharge prevention. The report cites Tesoro for not recording personnel training as required by page 22 of the Plan. Tesoro disputes this is a Class It violation. Tesoro maintains there is no violation. The regulatory requirement is for Tesoro to "train" its oil-handling personnel. § 112.7(f)(1). Tesoro is unaware of any SPCC requirement that mandates the records of training be recorded in a particular manner. As referenced on page 22 of the Plan, Tesoro maintains its employee training records in File 5.3 of the Environmental Files, an electronic file system that acts as "an equivalent format"to Table 10. As requested,Tesoro has enclosed training logs for 2013 through 2015. Item #704—CFR 112.8(c)(2) Dike area is not sufficiently impervious to contain discharged oil. Please see Tesoro's response to item #609. GVE� JAN 0 6 2616 ENo.V RONMENTAL WCAITU ncO1RTMFK1T 7