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Report all or <br /> chemical spllIs al <br /> 866-A24-8802 <br /> From: Carl Wenske [mailto:cww8400@aol.com] <br /> Sent:Wednesday, October 03, 2018 5:40 PM <br /> To:Witul,Janice<Witul.Janice@epa.gov> <br /> Cc: Dave Lounsbury<dlounsbury@wbecorp.com> <br /> Subject: Re: Bullfrog Landing Marina <br /> So sorry Janice that I did not respond in writing. I understood all that had to be done and complied.Tank five is empty, <br /> disconnected, locked and marked "OUT OF SERVICE". <br /> As for training: I CARL Wenske is the only one operating Bullfrog Marina. I do all mandatory inspection and much more. I <br /> live and work here. Last thing I want or need is a problem with fuel? <br /> As to Air Quality Control. All testing is completed by Donnelly Pump and they automatically contact us and schedule. <br /> As for me sending you the corrected SPCC plan,that was not me. It was our PE who made all corrections and sent that to <br /> you. <br /> Sent from my iPad <br /> On Oct 3, 2018, at 4:01 PM, Witul,Janice<Witul.Janice@epa.gov>wrote: <br /> To date, I have not received documentation that any of these issues from the May 31 SPCC Inspection by <br /> US EPA have been resolved: <br /> • Tank 5 UT inspection revealed that the tank is unsuitable for continued service. The <br /> tank should be permanently closed in accordance with the 40 CFR 112.2 definition <br /> - Permanently closed means any container or facility for which: (1)All liquid and sludge has <br /> been removed from each container and connecting line; and (2)All connecting lines and piping <br /> 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 <br /> stating that it is a 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 <br /> discharge prevention briefings for your oil-handling personnel at least once a year to assure <br /> adequate understanding of the SPCC Plan for that facility. Such briefings must highlight and <br /> describe known discharges as described in §112.1(b) or failures, malfunctioning components, <br /> and any recently developed precautionary measures. <br /> • Provide verification that tanks' configurations meet requirements for normal and <br /> emergency venting for aboveground fuel storage tanks. <br /> • Provide verification that tank testing performed for Air Pollution Control District meets <br /> all STI SP001 (industry standard specified in SPCC Plan) inspection/testing requirements. If the <br /> two-year testing schedule specified in SPCC Plan impracticability section is valid/necessary,tank <br /> testing should be performed as soon as possible. <br /> In addition,the SPCC Report (received by Certified Mail on 8/1/2018 by Carl Wenske) identified <br /> additional deficiencies with the SPCC and Contingency Plans and their implementation. None of those <br /> deficiencies have been addressed,to my knowledge. <br /> 3 <br />