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Ruvalcaba, Cesar From: Ruvalcaba,Cesar Sent: Thursday,August 1,2019 4:11 PM To: Vignon-Fernandez, Denisse' Subject: RE: Update APSA/SPCC inspection report response- 10100 W. Linne Road,Tracy- PR0515795 Attachments: Operating Equipement Oil Spill Contigency Plan (Guidance Only).pdf; Requirements for a Facility Diagram.pdf, Overfill Prevention.pdf, Open Violations.pdf, Environmental Equivalence cannot use existing requirements .pdf,, SP001 6th edition checklists (7).docx Hi Denisse, I was able to close some of the violations.An updated list of the open violations is attached. I brief explanation of why the violations were not closed is found below. Violation#301 -Failed to amend Plan as necessarv. Response submitted stated that there were several qualified oil-filled operational equipment added to the SPCC plan. The SPCC plan in section 5.4 Inspection,Tests,and Records states that"In addition,pursuant to 40 CFR§112.7(k)(2), Northwest Pipe Company has instituted alternative requirements to general secondary containment for its qualified oil- filled operational equipment._" Observations/comments: The addition of the oil-filled operational equipment must meet all the requirements of the SPCC regulations.40 CFR§112.7(k)(2)does allow the facility to choose alternate requirements instead of providing general secondary containment for the tanks.There are 3 requirements that have to be met if the general secondary containment is not provided. Per a quick review of the SPCC plan only one of the three requirements have been met. The table of contents and the cross reference sheet were used to try and find the discussions/documents. Furthermore the operational equipment is not represented in the facility map. Following are the regulations from which the decision not to close the violations was made 40 CFR§112.7(k)(2) (2) Alternative Requirements to General Secondary Containment. R secondary containment is not provided for qualified oil-filled operational equipment pursuant to paragraph (c)of this section,the owner or operator of a facility with qualified oil-filled operational equipment must: (i) Establish and document the facility procedures for inspections or a monitoring program to detect equipment failure and/or a discharge; and (ii) Unless you have submitted a response plan under§112.20, provide in your Plan the following: (If a response plan under 40 CFR §112.20 has been submitted to the EPA, provide written statement that this has been done) (A)An oil spill contingency plan following the provisions of part 109 of this chapter. (Guidance attached, checklist is not an oil-spilled contingency plan, a link to part 109 can be found here ) (B)A written commitment of manpower, equipment, and materials required to expeditiously control and remove any quantity of oil discharged that may be harmful. 40 CFR§112.7(a)(3) (3) Describe in your Plan the physical layout of the facility and include a facility diagram,which must mark the location and contents of each fixed oil storage container and the storage area where mobile or portable containers 1