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Ruvalcaba, Cesar From: Ruvalcaba,Cesar Sent: Friday,June 28,2019 4:18 PM To: 'Yang, Mark M.@CDCR' Cc: Prasad,Asveen@CDCR Albee, Phil@CDCR Medlin, Hettie@CDCR;Ayers,Gary@CDCR; Sahota, Paul@CDCR Subject: RE: Action Plan -APSA/SPCC inspection - 7707 Austin Rd - PR0538333 Attachments: 2.10.6 Oil-powered Generators ("Gen-sets").pdf, SP001 6th eddion checklists (7).docx Hi Mark, The latest return to compliance and SPCC plan have been reviewed. None of the violations have been closed. Below you will find an explanation as to why. Violation #301 — Failed to amend Plan as necessary. The SPCC plan states the following 4.3 Containment and Diversionary Structures (40 CFR 112.7(c)) Containment measures to prevent a discharge are described in Section 4.2 above. Secondary containment is provided for ASTs as discussed below in 4.3.2. Fuel spill cleanup supplies and materials (granular absorbents, absorbent mats, drums, absorbent booms, plastic sheets, etc.) are located at the Generator Yard location and listed below on Table 4-2. Section 4.2 discusses secondary containment for the tanks and does not describe what the secondary containment for the generators that hold 105 gallons of oil is. Section 4.3.2 states that "AST's at the CHCF— Stockton facility are of double walled construction as described in Table 3.1 and therefore not required to be located within additional secondary containment structures."Table 3.1 does not mention the generators holding the oil. I do see that the capacity for the generators is mentioned to have an internal capacity of 105 gallons. The generators may fall under the category of operational equipment, meaning that they may qualify for general containment. The operational equipment still needs to comply with all aspects of CFR 112.1 through 112.7 which can be found here. This would include section 112.7(c), general secondary containment, 112.7(a)(3), be included in the facility diagram (which I did not see). These are just a couple of examples of sections within 112.1 through 112.7. 1 have included guidance on generator sets (attached) and on operational equipment, here (pages 4-7 through 4-14) . The full guidance document can be found here. For the manifolded tanks, the certifying engineer should address the that the secondary , the total capacity of manifolded containers is the design capacity standard for the sized secondary containment provisions. The concern here is that the tanks act as a single unit, in the event of a release will the secondary containment system be able to hold the capacity of the combined manifolded tanks? The engineer needs to certify that secondary containment is adequate in this case for the combined totals, not just a single tank. The engineer may have several options, based on the type of tanks. Permanently manifolded tanks are tanks that are designed, installed, or operated in such a manner that the multiple containers function as a single storage unit (67 FR 47122, July 17, 2002). Accordingly, the total capacity of manifolded containers is the design capacity standard for the sized secondary containment provisions (plus freeboard in certain cases). here (page 4-17) The SPCC plan state the following The four 10,000-gallon and one 2,000-gallon ASTs, are constructed of double walled steel encased in a reinforced concrete vault. Fuel piping is above ground. Tank manifolds are connected between I