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Mr. Burgin The return to compliance and portions of the SPCC plan have been reviewed. The following violations require more clarification. I have include suggestions of what can be done to come into compliance. Violation 105 - Failure to properly close tanks when making a claim of permanently closed. Provide a statement that the closed tank also meets the following requirements. - remove all liquid and sludge from each containerand connecting line -disconnect and blankoff all connecting lines and piping havefrom thetank - close and lock all valves Violation 609 - Plan failed to adequately contain procedures for reporting a discharge. Thisviolation has been addressed sincethe correct numberforthe San Joaquin Envrionmental Health Department is found in the SPCC plan but the numberforthe San Joaquin County Environmental Health Department provided in Appendix A page A-2 is incorrect. The number is (209) 468-3420. Violation 618 - Failed to keep records of procedures, inspections, or integrity tests for three years. Provide statementthat assuresthe department that inspectionswill be conducted as perthe SPCC plan and the records will be retained as required or provide copies of the inspection reportsforthe monthly and annual inspections. Violation 711 - Failed to perform scheduled tank tests or inspections by appropriately qualified personnel. The inspection report should state whether or not the tank is suitable for continued use, this is a requirement forthe certified reports underthe SP -001 standard. The following is not part of the violation, but the SPCC plan was amended and may be a violation during the next inspection. I noticed that the SPCC plan no longer references an industry standard. The previous version of the SPCC plan referenced the STI SP -001 standard. It is a regulatory requirement that an industry standard be used to determine the appropriate qualifications for personnel performing tests and inspections, the frequency and type of testing and inspections. If the facility is to continue inspecting the tanks per the STI standard, it needs to state that in the SPCC plan, along with deviations from the standard, if any. Looking at the SPCC Inspection checklists provided to the facility, the checklists may not meet the requirements of the SP -001 standard. I have included the SP -001 standard checklists. As stated on the checklists, locally developed checklists are acceptable as long as they are substantially equivalent (as applicable). Inspections of multiple tanks may be captured on one form as long as the tanks are substantially the same. It seems like the SPCC plan does not included an annual inspection form forthe tanks, assuming that the standard will continue to be SP -001. The "frequent SPCC inspection" form may not meet all the requirements forthe most current SP -001 monthly checklist.. Feel free to contact me with any questions FREE classes presented by NES Inc. are available to all San Joaquin County Hazardous Waste, Underground Storage Tank, and Aboveground Petroleum Storage Facility Business Owners and Operators. List and schedule of classes can be found here. Thankyou, Cesar Ruvalcaba San Joaquin County Environmental Health Department Environmental Health Specialist