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Cesar Ruvalcaba [EH] From: Cesar Ruvalcaba [EH] Sent: Monday, February 4, 2019 4:20 PM To: 'Jordan Bottorff' Subject: RE: APSA/SPCC inspection report - PR0530029 Hi Jordan, I have reviewed the submitted return to compliance. I would recommend including the appropriate discussions on the appropriate plan sections/titles. For example, item #726 CFR 112.8(c)(8),the response leads to page 28 and 29 in the SPCC plan.The highlighted section in page 28 is under section 112.8(d)(4)which deals with inspections of valves, piping and appurtenances. The highlighted section of Page 29 is under section 112.12(c)(8). APSA does not regulate section 112.12 which are the requirements for animal fats and oils and greases, and fish and marine mammal oils; and for vegetable oils, including oils from seeds, nuts,fruits and kernels. Any discussion in this section (112.12)would not apply to sections 112.8 (unless referenced in the plan)which is part of the discussion for Petroleum oils and non-petroleum oils except for those mentioned in section 112.12. The violations are considered addressed based on the submitted return to compliance, with the exemption of the following: For Item #710 CFR 112.8(c)(6), it appears that the requirement has not been fully addressed in the SPCC plan. The referenced page 22 seems to be addressing the integrity testing of the internal floating roof ASTs at PES. In the sections that addresses CFR 112.7 (e) of the SPCC plan, there is a highlighted sentence in that paragraph which states that"PES has opted to perform the 5 year integrity tests and will complete according to API 653". The concern here is that the plan still does not fulfill the requirements of CFR 112.8(c)(6) which reads, in part, "...You must determine, in accordance with industry standards, the appropriate qualifications for personnel performing tests and inspections, the frequency and type of testing and inspections,which take into account container size, configuration, and design..." The SPCC plan does not specify the appropriate qualifications for the personnel performing tests and inspections.The frequency of the inspections, for the API 653, is given as every 5 years. Who will perform these inspections?Are these internal or external inspections?Section 6 of the API 653 standard references inspections from the outside of the tank (routine in service, external inspection, ultrasonic thickness, cathodic protection surveys) and internal inspections (tank bottom),the SPCC plan does not address any of this.The SPCC plan should state the appropriate qualifications of personnel conducting the inspections/tests,the frequency of any inspections/tests required by the standard and which tests or inspections are necessary for the tanks. According to the plan, the API 653 is only for internal floating roof ASTs.The other mentioned inspection is 40 CFR 60 subpart Kb, which seems to be for floating roofs and focused on VOC and not the integrity of the tank itself.The plan states that 40 CFR 60 subpart Kb is used in lieu of STI-SP001. If I remember correctly there are other tanks which do not have floating roofs. What industry standard are those tanks following?Similar discussion would need to be provided for the tanks that do not fall under the API 653 standard and which fall under a different standard. If 40 CFR 60 subpart Kb is being used for the smaller tanks, and the engineer certifies it, we do not have the authority to question the certification but it could be referred to the EPA for them to make the judgment of the appropriateness of 40 CFR subpart Kb to meet SPCC requirements. Feel free to contact me with any questions. i