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Ruvalcaba, Cesar From: Ruvalcaba,Cesar Sent: Thursday, September 12,2019 10:45 AM To: 'DPaul' Cc: 'Gary Del Carlo' Subject: RE: Haley's Flying Service submittals) - PR0515798 Attachments: used oiI.JPG; nurse tank 1.jpg; nurse tank 2.JPG; cross reference example.pdf Paul, Below is the response to the submitted return to compliance. Only portions of the SPCC plan that addressed the violations have been reviewed. It is understood that this was a draft version of the plan which has not been certified by a professional engineer,The San Joaquin County Environmental Health Department is just determining whether or not the SPCC plan meets the requirements of APSA regulations for the issued violations.There may be some clarification needed for portions of the Plan. Violation#301 -Failed to amend Plan as necessary. Based on the provided response, SPCC plan and photos. This may just need further clarification.During the inspection there was what appeared to be a 55 gallon drum of used oil,the drum is not mentioned in the SPCC plan.A picture of the drum taken during the inspection is attached. Asa general comment any tank that stored petroleum product and is 55 gallons or over must be in the SPCC plan.Only tanks that meet the definition of permanently closed do not have to be addressed.A permanently closed tank is on which meets the following requirements. (1)All liquid and sludge has been removed from each container and connecting line;and (2)All connecting lines and piping have been disconnected from the container and blanked off,all valves(except for ventilation valves) have been closed and looked,and conspicuous signs have been posted on each container stating that it is a permanently closed container and noting the date of closure. 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 on the truck 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 diesel while the truck is parked at the facility.General secondary containment requirements would apply,if it meets the definition of a mobile refeuler under 40 CFR 112. Picture is attached and labeled as"nurse tank 1".Same thing will apply to any other tanks on trailers,which meet the 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 tanks are"exempt". Violation#601 -Failure of Plan to fulfill basic requirements including a cross-referencing section. The current version of the plan does not follow the order or requirements in 40 CFR Part 112 and a cross-reference is not provided.An example,provided by the US EPA is attached,as"cross reference example" Violation#603-Felled to adequately describe the physical layout of the facility In the Plan. Facility diagram was not included. Violation#609-Plan failed to adequately contain procedures for reporting a discharge. The provided CalOES number is still incorrect.The 24 hour number for reporting spills is 1-800-852-7550.The provided number is for CalOES Office of Crisis Communications and Media Relations. The 24 hour phone number or name of the local CUPA is not provided.The San Joaquin County Environmental Health Department is the local CUPA and the 24 hour spill reporting number is(209)468-3420 Violation#612-Plan failed to Include secondary containment,diversionary structures,or equip to prevent discharge. Provide an explanation of why the nurse tanks described in violation 301 and attached pictures are"exempt"and not described in the SPCC plan.If the single walled 1,000 gallons tank does not meet the definition of permanently closed(see violation 301)it needs to be addressed in the plan and be in full compliance with APSA regulations, unless it has been removed. Violation#618-Failed to keep records of procedures, Inspections,or integrity tests for three years. Records have not been provided or statements assuring the department that future inspection records will be kept for three years have not been submitted. Violation#628-Failure to include in the Plan discussion of conformance with Federal and State requirements. 1