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Ruvalcaba, Cesar <br /> From: DPaul <spccorp@hotmaitcom> <br /> Sent: Thursday, September 12,2019 10:50 AM <br /> To: Ruvalcaba,Cesar, Gary delCarlo <br /> Subject: Re: Haley's Flying Service submittal(s) - PR0515798 <br /> Cesar: <br /> Please note several of the deficiencies described in your response were declared in our recent-submittal of the <br /> greenline edits. We will now incorporate those revisions as indicated in your response and prepare a Final <br /> submittal for your review. Thankyou. <br /> Paul <br /> SPC Corp <br /> From: Ruvalcaba,Cesar<cruvalcaba@sjgov.org> <br /> Sent:Thursday,September 12, 201910:44 AM <br /> To: DPaul<spccorp@hotmail.com> <br /> Cc: Gary Del Carlo<hfstracyca@msn.com> <br /> Subject: RE: Haley's Flying Service submittal(s)-PRO515798 <br /> Paul, <br /> Below is the response to the submitted return to compliance. Only portions of the SPCC plan that addressed the <br /> violations have been reviewed. It is understood that this was a draft version of the plan which has not been certified by <br /> a professional engineer.The San Joaquin County Environmental Health Department is just determining whether or not <br /> the SPCC plan meets the requirements of APSA regulations for the issued violations.There may be some clarification <br /> needed for portions of the Plan. <br /> Violation#301-Failed to amend Plan as necessary. <br /> Based on the provided response,SPCC plan and photos. <br /> This may just need further clarification.During the inspection there was what appeared to be a 55 gallon drum of used oil,the done is not mentioned <br /> in the SPCC plan.A picture ofthe drum taken during the inspection is attached. As a general comment any tank that stored petroleum product and is <br /> 55 gallons or over at be in the SPCC plan.Only tanks that meet the definition of permanently closed do not have to be addressed.A peormently <br /> closed tank is on which is the following requirements. <br /> (1)All liquid and sludge has been removed from each container and connecting line;and <br /> (2)All connecting lines and piping have been disconnected from the container and blanked off,all valves(except for ventilation valves)have been <br /> closed and lacked,and conspicuous signs have been posted on each container stating that it is a permanently closed container and noting the date of <br /> closure. <br /> There are several tanks which are shown in the provided pictures but are not mentioned in the SPCC plan.For example the 1,000 gallon diesel tank <br /> on the track with a 2,000 gallon chem-tank,described in the pictures as Mobile Nurse Tank.The diesel tank would need to be addressed if it stores <br /> diesel while the track is parked at the facility.General secondary containment requirements would apply,if it meets the definition of a mobile <br /> refenler under 40 CFA 112.Picture is attached and labeled as"nurse tank 1".Same thing will apply to any other tanks on hailers,which meet the <br /> definition of a mobile refueler.(the 500 and 1,500 mobile tanks,picture labeled as nurse tank 2)Provide an explanation as to why these ranks are <br /> ""fit,. <br /> Violation#601-Failure of Plan to fulfill basic requirements including a cross-referencing section. <br /> The current version of the plan does not follow the order or requirements in 40 CFA Part 112 and a cross-reference is not provided.An example, <br /> provided by the US EPA is attached,as"cross reference example" <br /> Violation#603-Failed to adequately describe the physical layout of the facility in the Plan. <br /> Facility diagram was not included. <br /> Violation#609-Plan failed to adequately contain procedures for reporting a discharge. <br /> 1 <br />