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Ruvalcaba, Cesar <br /> From: Yang, Mark M.@CDCR <Mark.Yang@cdccca.gov> <br /> Sent: Tuesday,July 2,2019 10:23 AM <br /> To: Ruvalcaba,Cesar <br /> Cc: Prasad,Asveen@CDCR Albee, Phil@CDCR Medlin, Hettie@CDCR;Ayers,Gary@CDCR; <br /> Sahota, Paul@CDCR;Vasquez, Paul@CDCR <br /> Subject: RE: Action Plan -APSA/SPCC inspection - 7707 Austin Rd - PR0538333 <br /> Attachments: CHCF's SPCCP revision.pdf <br /> Good Morning Cesar, <br /> Per our telephone conversation this morning,we have updated CHCF's SPCCP per discussion as you suggested for your <br /> view. Page 3 is the generator motor and piping containments,page 4 is table 3-1 included the 6 generators, page 6 <br /> table4-1 the generator,and page 7 described the 6 engine enclosure/containments. <br /> Also,the map and figures enclosed too along with Appendix A. Please review the revised CHCF's SPCCP and then let us <br /> know if further revision is needed before we send out for certification by a registered engineer.Your help and assistance <br /> is greatly appreciated. <br /> Thank you, <br /> Mark <br /> From: Ruvalcaba, Cesar [rreilto:cmvalcaba@sjgov.org] <br /> Sent: Friday, June 28, 2019 4:21 PM <br /> To: Yang, Mark M.@CDCR <br /> Cc: Prasad, Asveen@CDCR; Abee, Phil@CDCR; Medlin, Hettie@CDCR; Ayers, Gary@CDCR; Sahota, Paul@CDCR <br /> Subject: RE: Action Plan - APSA/SPCC inspection - 7707 Austin Rd - PRO538333 <br /> Hi Mark, <br /> The latest return to compliance and SPCC plan have been reviewed. None of the violations have <br /> been closed. Below you will find an explanation as to why. <br /> Violation #301 — Failed to amend Plan as necessary. <br /> The SPCC plan states the following <br /> 4.3 Containment and Diversionary Structures (40 CFR 112.7(c)) <br /> Containment measures to prevent a discharge are described in Section 4.2 above. Secondary <br /> containment is provided for ASTs as discussed below in 4.3.2. <br /> Fuel spill cleanup supplies and materials (granular absorbents, absorbent mats, drums, absorbent <br /> booms, plastic sheets, etc.) are located at the Generator Yard location and listed below on Table 4-2. <br /> Section 4.2 discusses secondary containment for the tanks and does not describe what the <br /> secondary containment for the generators that hold 105 gallons of oil is. Section 4.3.2 states that <br /> "AST's at the CHCF— Stockton facility are of double walled construction as described in Table 3.1 <br /> and therefore not required to be located within additional secondary containment structures."Table <br /> 3.1 does not mention the generators holding the oil. I do see that the capacity for the generators is <br /> mentioned to have an internal capacity of 105 gallons. The generators may fall under the category of <br /> operational equipment, meaning that they may qualify for general containment. The operational <br /> I <br />