COMPLIANCE INFO_PRE 2019 - Laserfiche WebLink

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The Terminal's SPCC plan was provided for your review during the inspection. The SPCC plan is updated on an annual basis for minor personnel and contact information changes. In addition, it is updated as required by Federal SPCC regulations, 40 CFR 112. The SPCC plan is currently being updated to coincide with the revised SPCC regulations, which until just recently were to go in to effect on August 17, 2004. (The U.S. Environmental Protection Agency recently proposed extending the compliance deadline for another year. See Federal Register, June 17, 2004). As discussed in the item #45 above, I understand from our June 23, 2004 phone conversation that the SJCEHD does not consider this item a violation, but rather refers to it as "Notes" in the comments and write up portion of the inspection report. Tesoro maintains that the Terminal is in compliance and does not agree that a Certification of Return to Compliance is required. Tesoro requests that the SJCEHD rescind this requirement. Tesoro will notify the SJCEHD in writing when the SPCC plan updates are complete and will provided copies upon request. Notes #2 Environmental Health Department Generator Permit As stated in the Notes portion of the inspection report, the Terminal did not transport hazardous waste off site in 2003. The current SJCEHD permit identifies the Terminal as a 5-25 ton generator. Tesoro understands that we may modify our generator status with the SJCEHD to a lower generator status. If we determine that this is preferable, we will submit such written request to the SJCEHD. Notes #3 Tier Permit Facility The SJCEHD currently has the Terminal listed a Tier Permit Facility. Treatment of hazardous waste does not occur at the Terminal. Tesoro operated an Activated Carbon Treatment Unit for a short time but deactivated this permit in 1996. The California Department of Toxic Substances Control approved the closure of this unit in March 1996. The Tier Permit can be inactivated. Closing As stated previously, Tesoro does not believe that the Terminal is out of compliance for any of the items in your inspection report and does not agree that a Certification of Return to Compliance needs to be completed. Tesoro requests that this requirement be rescinded. We will notify the SJCEHD in writing when the SPCC and Hazardous Waste Contingency Plan updates are completed. Please contact me at 253-896-8735 if you should have questions or require additional information. Thank you for your assistance. Sincerely, ce&V"-W Catherine Runden Environmental Administrator Tesoro Petroleum Companies, Inc.