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Ruvalcaba, Cesar From: Denisse Vig non Fernandez <DVIGNON@nwpipe.com> Sent: Wednesday, December 11,2019 10:36 AM To: Ruvalcaba,Cesar Subject: Northwest Pipe Company SPCC update Attachments: RE: Emergency Contingency Plan question; 2019-11-25 SPCC Table 2- Oil Container Testing Potential Discharge Info w-SHS comment.docc; HWCP 2020.pdf Hi Cesar, Sending this email as follow up for SPCC progress and attached response to HMBP concern: The first document is the HMBP updated to reflect how we meet 109 requirements; I believe this document has to be attached to the CERS system,so I wanted to get your feedback prior to submission; as you mentioned before,this document intends to comply with multiple programs,but as a minimum, I hope it meets requirement (A)highlighted below The 2ntl document is a summary of oil containers that is planned to be added to the latest revision of SPCC plan;this is a reference document on HMBP. Please get back with any questions and concerns. Thanks Denisse From: Ruvalcaba,Cesar<cruvalcaba@sjgov.org> Sent:Thursday,August 1,2019 4:11 PM To:Vignon-Fernandez, Denisse<DVIGNON@nwpipe.com> Subject: RE: Update APSA/SPCC inspection report response-10100 W. Linne Road,Tracy-PR0515795 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 necessary. 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 4112.7(k)(2) 1