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Ruvalcaba, Cesar From: Ruvalcaba,Cesar Sent: Thursday, September 12,2019 12:00 PM To: Wrtu 1,Janice Cc: Manzo, Elena K. Subject: San Joaquin County SPCC question- Hybrid Inspection Attachments: SPCCpIanHaleyFlying Jan2011 FinalDrak.pdf, Return to compliance comments.pdf, HaleysFlyingSvc2019.p ptx Hi Janice, Hope everything is well. Our APSA department in San Joaquin County has grown a bit,we now have another inspector and a dedicated supervisor, Elena Manzo,who is cted in this email.We have come across a SPCC plan that is currently being revised which is claiming an environmental equivalence for 112.8(c)(6).This is the first time that we deal with a hybrid inspection program and wanted to get your opinion on it since the EPA has the authority to request changes if needed. First a little background on the situation.The company writing the plan,Spill Prevention Compliance Corporation (SPC Corp),was utilizing the described techniques from the hybrid plan in another location within our jurisdiction.They would issue a"SP-001 complaint certificate", even when the plan called for a SP-001 certified inspection.This certificate was sent to STI. STI and SPC Corp agreed that all references to STI would be removed from the certificate.SPC Corp has agreed that if a plan calls for STI inspections,it will be conducted under STI guidelines and issue an STI certified report. Part of the issue with the inspection they performed was that they failed to identify a UST that was being used as an AST.This was referred to the local fire jurisdiction,they were able to locate a UL listing which identified the tank as a former UST.They were using the same technique described in the hybrid plan that is attached. For this facility in question,SPC Corp is choosing to call out UL industry standards 142, 2080,2085 and 2245.These, I believe are construction standards for a tank and not integrity inspection/testing standards.They are also utilizing what they call their patented 2-stage procedure to inspect the inside(double walled)and outside(single walled)of the tanks and STI guidelines for steel thickness. Portions of the SPCC plan dealing with the tanks,the hybrid procedure and inspection checklists are attached. More information has been requested,such as why 21 CFR part 110 is called out for the inspection of the tanks and how the rest of the tanks will be inspected at the facility.They have been asked to include the qualifications of the personnel who should be performing the testing/inspections.The hybrid plan addresses two of the tanks,a 10,000 double walled tank and a 1,000 gallon single walled but the facility has several other smaller tanks.The 1,000 gallon single walled tank is to be removed from the facility since they don't have secondary containment. Would the EPA consider the hybrid plan acceptable?Although the plan does not state it, SPC Corp views this a the equivalent or better than the STI standard,based on the attached return to compliance certification comments for that violation. I believe that the return to compliance comments will be incorporated into the SPCC certified plan. Attached are pictures provided by SPC Corp. I've asked for an explanation why certain tanks are marked as exempt. During the inspection it was stated that tanks on trailers/trucks were parked with fuel in them. I believe the facility would be under EPA jurisdiction, based on its location.This is an aerial application company and not a farm. Haley Flying Services 15971 S TRACY BLVD Tracy,CA 95304 1