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Cesar Ruvalcaba [EH] <br /> From: Witul, Janice <Witul.Janice@epa.gov> <br /> Sent: Thursday, October 18, 2018 4:34 PM <br /> To: Dave Lounsbury; Carl Wenske <br /> Cc: Cesar Ruvalcaba [EH]; Dave Ressa <br /> Subject: RE: Bullfrog Landing Marina <br /> Dave— <br /> I would like clarification on the testing that has been conducted on the tanks. I do see that the schedule for <br /> inspection/testing has been revised, so that the SPCC Plan shows the same time frame as the Vapor Recovery System <br /> Tests. <br /> The issue in question is whether those tests required by the Air Resource Board meet the requirements for STI SP001 <br /> tests. Category 3 tanks require periodic AST inspections by the owner's inspector, as well as Formal External Inspections <br /> and Leak Tests by Certified STI Inspectors, and 40 CFR 112.7(d) requires periodic integrity and leak testing of the valves <br /> and piping. <br /> Please provide documentation that shows that the STI SP001 Section 7 Formal External Inspections and Section 9 Leak <br /> Testing procedure (as detailed in Recommended Practice R912) requirements have been satisfied for the tanks,valves, <br /> and piping. If this is not the case, those tests are necessary for the facility to be in compliance with SPCC regulations. <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 all or <br /> chemical spllIs al <br /> �66�2d-SSO� <br /> From: Dave Lounsbury [mailto:dlounsbury@wbecorp.com] <br /> Sent:Tuesday, October 16, 2018 2:39 PM <br /> To: Witul,Janice<Witul.Janice@epa.gov>; Carl Wenske<cww8400@aol.com> <br /> Cc: Cesar Ruvalcaba [EH] <cruvalcaba@sjcehd.com>; Dave Ressa <jawsdumdum@aol.com> <br /> Subject: RE: Bullfrog Landing Marina <br /> Ms. Witul: <br /> Attached is a copy of a letter which provides a response to the deficiencies identified pursuant to your inspection of the <br /> facility and review of the documents. <br /> Please let me know if you would like to receive a copy of the updated SPCC or the OSC Plans which were revised to <br /> address the noted issues. <br /> Thank you very much, <br /> -Dave <br />