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Cesar Ruvalcaba [EH] <br /> From: Witul, Janice <Witul.Janice@epa.gov> <br /> Sent: Friday,June 1, 2018 10:13 PM <br /> To: jim uhl <br /> Cc: dlounsbury@wbecorp.com; Cesar Ruvalcaba [EH] <br /> Subject: EPA Inspection follow-up <br /> Attachments: Bullfrog Landing Deficiencies.pdf; Bullfrog Landing NOI.pdf <br /> A few items from the 31 May inspection. As noted, I do need an electronic copy of the SPCC Plan and the Contingency <br /> Plan to review thoroughly in order to finish my report. <br /> To clarify some of the items shown as deficiencies on the attached Summary of SPCC Deficiencies- <br /> • Tank 5 UT inspection revealed that the tank is unsuitable for continued service. The tank should be <br /> permanently closed in accordance with the 40 CFR 112.2 definition - Permanently closed means any container or <br /> facility for which:(1)All liquid and sludge has been removed from each container and connecting line;and(2)All <br /> connecting lines and piping have been disconnected from the container and blanked off, all valves(except for ventilation <br /> valves)have been closed and locked,and conspicuous signs have been posted on each container stating that it is a <br /> permanently closed container and noting the date of closure. <br /> • Training needs to be documented per 40 CFR 112.7(f)(3) -Schedule and conduct discharge prevention <br /> briefings for your oil-handling personnel at least once a year to assure adequate understanding of the SPCC Plan <br /> for that facility. Such briefings must highlight and describe known discharges as described in §112.1(b) or <br /> failures, malfunctioning components, and any recently developed precautionary measures. <br /> • Provide verification that tanks' configurations meet requirements for normal and emergency venting for <br /> aboveground fuel storage tanks. <br /> • Provide verification that tank testing performed for Air Pollution Control District meets all STI SP001 <br /> (industry standard specified in SPCC Plan) inspection/testing requirements. If the two-year testing schedule <br /> specified in SPCC Plan impracticability section is valid/necessary,tank testing should be performed as soon as <br /> possible. <br /> Janice Witul - US EPA R9 <br /> Oil Program <br /> 75 Hawthorne St., ENF-3-2 <br /> San Francisco CA 94105 <br /> 415 972 3089 <br /> fax 415 947 3519 <br /> Report oil or <br /> chemical spills at <br /> 800-424-8802 <br /> 1 <br />